Bright Hope is committed to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, this policy allows employees to raise concerns about suspected misconduct, dishonesty, and fraud and to provide reassurance that they will be protected from reprisals for whistleblowing in good faith.

PROCEDURE

Reporting

Employees and any other person (“reporter”) who has a concern relating to suspected misconduct, dishonesty or fraud may make a report. Bright Hope wants to hear of possible problems in these areas. Every effort will be made to protect the identity of the reporter to the greatest extent possible. Completely anonymous reports will be accepted but a full investigation may be hindered by the inability to gather additional facts and information from the reporter. The creditability of an anonymous complaint may also affect the investigation process.

Examples of matters to be reported under this policy include financial reporting, accounting, internal accounting controls, auditing matters, or any other form of misconduct, dishonesty, or fraud. Please note that any matters that are clearly covered under our separate Human Resources policy manual will be handled by the process outlined therein and are not covered by this policy.

Concerns or suspected misconduct, dishonesty or fraud may be reported by email or in writing at the employee’s or reporter’s preference to the following officials.

  • C.H. Dyer, President;
  • Board Chairperson:

To mail in written concern(s), send to C.H. Dyer and/or the Board Chairperson at

Bright Hope, 2060 Stonington Ave., Hoffman Estates, IL 60169

Timing

The earlier a concern is expressed, the easier it is to take action.

Good Faith

It is expected that all reports provided in accordance with this policy will be made in good faith. This can include situations where there is a reasonable basis for suspicion without having conclusive evidence. However, any reports that are knowingly false and/or made with malicious intent and a reckless disregard for the truth will be disciplined accordingly.

Investigating the Concern

Following the receipt of any complaints submitted, the President or Board Chairperson to whom the report is submitted will be responsible to investigate the matter, though he/she may enlist the assistance of another person(s) at his/her discretion.  Any such person must be unrelated to the concern reported.  Under no circumstance will a person related to the concern reported be engaged as an investigator.  Further, when deemed appropriate, the investigation may include the engagement of Bright Hope’s external auditors. If a third party is to be engaged to serve in the investigation process, the Board of Directors must approve engaging the third party. A report of the investigation will be delivered to the full Board of Directors who will investigate each matter so reported and take corrective and disciplinary actions where appropriate.  If the report concerns a member of the Board of Directors, the member will be excluded from all related communication until a determination is made to address the matter with the individual.

Communication with Reporter

The amount of contact between the reporter and those investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the reporter. The reporter will be given the opportunity to receive follow-up on their concern within a reasonable time frame:

  • Acknowledging that the concern was received.
  • Indicating how the matter will be dealt with.
  • Giving an estimate of the time that it will take for a final response.
  • Telling them whether initial inquiries have been made; and
  • Telling them whether further investigations will follow, and if not, why.

Information

Subject to legal constraints the reporter will receive information about the outcome of any investigations.

Document Retention

The Board of Directors shall retain records of the complaints or concerns for a period of at least seven years.

SAFEGUARDS

No Retaliation

No director, officer, or employee or other person who in good faith reports a violation shall suffer harassment, retaliation, or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and others to raise concerns within the organization prior to seeking resolution outside the organization.

Additionally, no employee shall be adversely affected because they refuse to carry out a directive which, in fact, constitutes corporate fraud, is a violation of state or federal law, and/or is against Bright Hope’s ministry policy.

DEFINITION OF TERMS

For purposes of this policy, the definition of misconduct, dishonesty, and fraud includes but is not limited to:

  • Acts which are inconsistent with ministry policy
  • Theft or other misappropriation of ministry assets
  • Misstatements or other irregularities in ministry records
  • Incorrect financial reporting
  • Misuse of ministry resources
  • Illegal activities
  • Immoral or unbiblical activities
  • Forgery or alteration of documents
  • Any other form of fraud

Bright Hope reserves the right to modify or amend this policy at any time as it may deem necessary.