WhistleBlower Policy

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Statement

The Cornerstone Montessori Prep School and the Children’s Primary Centre(“Cornerstone”) is
committed to the principles of integrity, accountability, transparency and honesty.
Therefore, Cornerstone requires employees, contractors, volunteers, board members and parents to
observe high standards of business and personal ethics in the conduct of their duties and
responsibilities.

Purpose

The purpose of this policy is to establish procedures for the anonymous reporting and investigating of
concerns when they discover information which they believe portrays serious or unethical conduct and
wrongdoing at Cornerstone. It is intended to encourage and enable Complainants to raise serious
concerns within Cornerstone.
This policy is intended to provide guidelines and a safe environment where employees are encouraged
to speak up or raise issues that have serious concerns or implications without risk of discrimination,
reprisal, or disclosure of their identities where prior consent is not given.

Scope

This Policy applies to all Cornerstone employees, contractors, volunteers, board members and parents.

Administration

The Whistleblower Program is managed by an appointed member of the Cornerstone Board.
Complaints can be anonymously reported via submission to the designated e-mail. The Cornerstone
Board member will initiate the investigation; this will include informing the School Principal as
appropriate, and assigning appropriate staff and/or other Board members to investigate the
Whistleblower complaint.

Reportable Activity

“Reportable Activity” covers instances where a Complainant/Whistleblower has evidence of activity by
any Cornerstone employee, contractor/retained consultant, volunteer, board member, parent, that to
his/her knowledge constitutes (but not limited to):
● Accounting, auditing, or other financial reporting fraud or misrepresentation
● Violations of federal or provincial laws that could result in fines or civil damages payable by
Cornerstone, or that could otherwise significantly harm the Cornerstone’s reputation or public image
● Unethical activities and conduct in violation of any Cornerstone policy
● Danger to the health, safety, or well-being of employees, volunteers, students and/or the general
public (including any real or perceived threat of workplace violence or harassment)

Accountability

School Principal

The School Principal is accountable for:
• Ensuring Cornerstone retains a Whistleblower Program with services that include procedures for
receiving, assessing, appropriately investigating and reporting the outcome of allegations and
complaints received under the Whistleblower Program
• Ensuring staff cooperate with Whistleblower Program investigations as required;
• Where applicable, ensuring the underlying causes are determined and that recommendations are
made to correct the situation and prevent further occurrences, and
• Where appropriate to the circumstances, inform the Board of Whistleblower Program investigations
and/or outcomes

All Employees, Volunteers, Board members

All Employees,Volunteers, Board members are accountable for:
• Complying with this policy
• Reporting any occurrence or indication of wrongdoing that they are aware of to their manager/
supervisor or other management staff through established channels or, where fear of reprisal exists,
through the whistleblower program, and
• Cooperating with whistleblower program investigations as required.

Process

All Employees have a responsibility to report serious violations or breaches of Cornerstone policies and
procedures; allegations of criminal activity; and any other Employee misconduct which may be
detrimental to the Cornerstone’s interests. Employees are encouraged to report such matters to their
supervisor using established channels, but may report them anonymously through the Whistleblower
Program when they fear reprisal. An independent, objective and impartial investigation of any
suspected acts or allegations of wrongdoing will be conducted, regardless of the Subject Party’s
position, title or length of service or the relationship with Cornerstone of any party who might be
involved in such an investigation.

Reporting Mechanism

The reporting system, accessible 24 hours a day, 7 days a week by email which only the designated
Cornerstone Board member will have access, to ensure strict confidentiality and anonymity. Information
on how to access the reporting system is available on the Cornerstone website. Whistleblowers are not
required to provide their name or any other personal information when submitting a complaint of
suspected wrongdoing by a Subject Party(s). However, in some cases, investigation may not be
possible unless the source of the information is identifiable and/or if insufficient information has been
provided.

Reporting Process

An anonymous report is submitted via e-mail accessible only by the designated Cornerstone Board
member. The Whistleblower should include as much information as possible, including the nature of
the wrongdoing; which employees are alleged to be involved; specific dates, times and locations; and
any relevant evidence.
The submission is assigned a confidential code. The designated Cornerstone Board member may
request additional information.

Handling of Reported Violations

The designated Cornerstone Board member will acknowledge receipt of the complaint within five (5)
business days.

Investigation

All complaints will be investigated. The investigation will be led by the designated Cornerstone Board
member. In all cases, an appropriate, qualified independent investigating subcommittee will be
established to conduct an objective investigation. The designated Cornerstone Board member and
Principal, in consultation with another Board member, will make this determination of the membership of
the investigating subcommittee, which may include Cornerstone staff and/or Board members as
appropriate.
In all cases, the person who is alleged to have committed the infraction set out in the complaint will be
made aware of the complaint at an appropriate point during the investigation.
Anonymous two-way communication with the Whistleblower is facilitated if more information is needed.
Disclosure of Whistleblower identity may be required only to the extent necessary to conduct a
complete and fair investigation.
The Whistleblower will be informed of the progress and resolution of the complaint via e-mail.

Conclusion

At the conclusion of each investigation, the staff investigator and appointed Cornerstone Board member
will document the results in a confidential report and provide the report to the Principal. The Principal
will make every reasonable effort to redress the concerns.
All complaints and any resulting investigations will be retained by Cornerstone in a confidential location
for a period of not less than five (5) years.

Protection from Reprisals

Unsubstantiated complaints made in good faith will not result in any reprisal against the Whistleblower
or the Subject Party, including:
• Dismissal or threat of dismissal
• Discipline or suspension or the threat of discipline or suspension
• Subjecting the employee to any form of harassment or abuse, or
• Imposing any penalty, directly or indirectly, including career limitations or change in work conditions/
assignment

Confidentiality

Confidentiality of the Subject Party
A Subject Party(s) accused of wrongdoing is innocent until proven guilty and entitled to due process.
The decision to inform the Subject Party(s) of the allegation or the investigation will be at the discretion
of the investigator(s) and will be determined on a case-by-case basis. The identity of the Subject
Party(s) will be confidential and only made known on a need-to-know basis in order to conclude the
investigation.

Confidentiality During Investigation

Whistleblowers, witnesses, the Subject Party(s), investigators and employees interviewed as part of an
investigation must maintain confidentiality of all information related to an investigation. Breaches of
confidentiality may be regarded as serious misconduct and will be subject to disciplinary action, in
accordance with this policy.

Acting in Good Faith

Any and all Complainants must be acting in good faith and have reasonable grounds for believing the
information disclosed indicates a Reportable Activity or suspected Reportable Activity.
Any allegations that prove not to be substantiated and which proved to have been maliciously or
knowingly to be false will be viewed as a serious disciplinary offense. Next steps will be handled on a
case by case basis including recommendations from the investigating subcommittee.
Employees who knowingly make a false or misleading statement; seek reprisal against an individual as
the result of a complaint; do not cooperate during the course of an investigation or complaint of
retaliation; or against whom acts of wrongdoing are substantiated will be subject to disciplinary action,
up to and including dismissal.

Reports

The Principal will provide a high-level summary of the complaints received and investigations
conducted in an annual report to the Board.