APPENDIX A: REPUBLICAN PARTY OF FLORIDA WHISTLEBLOWER POLICY¶
The Republican Party of Florida (“RPOF”), consistent with its commitment to maintain the highest standards of ethics, integrity, and compliance with the law has established this Policy governing the handling of Whistleblower claims. This Whistleblower policy applies to all RPOF officers, employees, members of the State Republican Executive Committee (“REC”), and contractors.
It is the policy of RPOF to investigate and appropriately respond to claims, complaints and allegations of RPOF employees, officers, REC members and contractors regarding any failure by RPOF to meet its legal and ethical obligations. A “Whistleblower” is any individual who notifies RPOF management of a claim, complaint or allegation of any failure to meet applicable legal or ethical obligations, such as the types of allegations in the list following below. No adverse action should be taken against an RPOF Whistleblower employee in retaliation for any actions taken by the employee consistent with this Policy in reporting a suspected violation of law or RPOF policy, so long as the Whistleblower employee reasonably believed the information reported to be accurate. The following list of possible subjects of Whistleblower reports is not exhaustive or intended to limit the scope of this Policy.
Unlawful conduct, practices or activities.
Violations of any RPOF policy.
Inappropriate use of RPOF funds or other resources.
Misappropriation, falsification, alteration or destruction of RPOF records.
Conduct, practices or activities that are inconsistent with generally accepted accounting principles.
Reporting Responsibilities¶
RPOF employees, officers, REC members, or contractors suspecting legal or policy violations must report such information to their supervisors, or if it is impractical or inappropriate to notify the supervisor, the information should be reported to the Executive Director, General Counsel or Chairman of the Audit Committee as appropriate. Reports of suspected impropriety should be forwarded by the supervisor or other officer or employee to the General Counsel who shall receive the information and endeavor to keep the information and identity of the source confidential, except in such instances where the General Counsel has a legal, ethical or fiduciary duty to inform others. Any party who has reason to believe that a serious breach of law or policy has occurred, shall retain all documents or other items that may be relevant to an investigation.
Supervisor Responsibilities¶
Supervisors who become aware of possible violations of law or RPOF policy, shall report such information to the General Counsel, or if impractical or inappropriate, the Executive Director or RPOF Chairman, at the earliest possible time.
Investigations¶
The General Counsel, or Executive Director as appropriate, is responsible for conducting an investigation of all matters reported pursuant to this Policy. During the course of any such investigation, employees, officers, contractors or REC members should not be suspended, terminated, removed, interrogated, disciplined or otherwise notified of the pending investigation until the supervisor has been instructed to do so by the General Counsel and the Executive Director.
Investigations shall include a review of all relevant documents and a diligent effort to interview all individuals believed to have knowledge of the facts and circumstances forming the substance of the allegations. During the course of an investigation, reasonable steps shall be taken to safeguard against unfounded accusations. At the conclusion of the investigation, the General Counsel shall report the findings of the investigation to the RPOF Chairman and Executive Director, and if appropriate, the Chairman of the Audit Committee.
Corrective or Disciplinary Action¶
Corrective or disciplinary actions shall be determined by the RPOF Chairman in consultation with the General Counsel, Executive Director, and if appropriate, the Executive Board. Appropriate corrective or disciplinary actions shall be determined on a case by case basis as warranted by the circumstances. The RPOF Chairman should consider whether any such violation was intentional, the harm caused by the violation, whether the party responsible for the violation has cooperated with the investigation, and whether the party responsible for the violation has voluntarily taken corrective action.