Sanford Consortium for Regenerative Medicine Whistleblower Policy and Procedure for Reporting Potentially Improper Business Conduct or Activities
The Sanford Consortium for Regenerative Medicine is committed to maintaining the highest possible standards of ethical, moral, and legal business conduct. Consistent with this obligation and the Sanford Consortium for Regenerative Medicine’s commitment to open communication, this policy establishes an open, easy, process for employees to raise concerns and to be reassured that they will be protected from reprisals for raising concerns.
The Sanford Consortium for Regenerative Medicine supports and expects employees who may have concerns about incorrect financial reporting or improper conduct by Sanford Consortium for Regenerative Medicine personnel to report such matters using the mechanism described in this policy. Concerns include, but are not limited to, any action that may be considered to be unlawful or any action judged to be inconsistent with other Sanford Consortium for Regenerative Medicine policies, including
the accounting policy. Employees who make good faith reports will not suffer reprisals of any kind.
This Sanford Consortium for Regenerative Medicine policy does not apply to administrative and research employees of the member institutions who may be located in the Sanford Consortium for Regenerative Medicine building and who may have concerns about actions taken by employees of their home institutions, pertaining either to research or administrative
(e.g., personnel, financial, etc.) matters; such concerns should be reported directly through the Whistleblower mechanisms established by their home institution.
This policy applies to all individuals working for the Sanford Consortium for Regenerative Medicine, including full-time, part time, temporary, visiting and those under contract.
a. Harassment or Victimization: Harassment or victimization of the complainant will not be tolerated.
b. Confidentiality: Every effort will be made to protect the complainant’s identity.
c. Anonymous Allegations: This policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:
- The seriousness of the issue raised;
- The credibility of the concern; and
- The likelihood of confirming the allegation.
d. Malicious Allegations: This policy precludes malicious allegations, and such allegations may result in disciplinary action.
a. Reporting: The following reporting procedures are intended to enable the communication of irregular financial reporting, and/or unethical or illegal conduct:
- Phone: Sanford Consortium for Regenerative Medicine President (858-246-1072) or Sanford Consortium for Regenerative Medicine Chief Operating Officer (858-246-1101) or Sanford Consortium for Regenerative Medicine Chief Financial
Officer (858-558-8530) – callers to the Hotline may choose to remain anonymous.
- Mail: address to Sanford Consortium for Regenerative Medicine President or Sanford Consortium for Regenerative Medicine Chief Operating Officer or Sanford Consortium for Regenerative Medicine Chief Financial Officer, and
mail to 2880 Torrey Pines Scenic Drive, La Jolla, CA 92037.
- Website link located on the Sanford Consortium for Regenerative Medicine homepage: www.sanfordconsortium.org
Please note that information provided in a report may form the basis of an internal and/or external investigation into the reported issue and anonymity will be protected to the extent possible by law. However, it is possible that the identity of an employee may become known during the course of a following investigation. Complaints will be submitted to the chairperson of the Sanford Consortium for Regenerative Medicine’s Governing Board and the chairperson of the Sanford Consortium’s Audit Committee, and may or may not be investigated in a manner deemed appropriate and at the sole discretion of the Sanford Consortium’s Audit Committee.
b. Timing: The earlier a concern is expressed, the easier it is to take action.
c. Evidence: Although an employee is not expected to prove the truth of an allegation, the employee report should demonstrate that there are sufficient grounds for concern.
6. HOW THE COMPLAINT WILL BE HANDLED
a. Overview: Actions taken will depend on the nature of the concern. The Audit Committee of the Sanford Consortium for Regenerative Medicine will receive a report describing each complaint, determine investigatory methods, and receive a follow-up report on findings and actions taken, if any.
b. Initial Inquiries: Initial inquiries will be made to determine whether an investigation is appropriate, and the form that is should take. Some concerns may be resolved by agreed action without the need for investigation.
c. Report to Complainant: All non-anonymous complainants will receive follow-up contact pertaining to their concern:
- Acknowledging that the concern was received;
- Indicating the method, if any, by which the complaint will be investigated;
- Giving an estimate of the time that it will take for a final response; and
- Subject to legal constraints, the complainant will receive information about the outcome of any germane investigation.
d. Further Information: The extent of contact between the complainant and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the complainant has remained accessible for follow-up.