Whistleblower Policy

Preamble

The Society of Environmental Toxicology and Chemistry (SETAC) is committed to high standards of scientific, ethical, moral and legal business conduct. In line with this commitment, SETAC requires SETAC governance members, employees, members, volunteers and guests (including exhibitors and sponsors) to adhere to high standards of personal and professional ethics in the conduct of their duties and responsibilities. 

Consistent with SETAC commitment to open communication, this policy aims to provide an avenue for anyone to raise concerns so that SETAC can address and correct inappropriate conduct and actions. Further, this policy provides such individuals reassurance that SETAC will endeavor to protect them from any reprisals or victimization for whistleblowing.

Concerns covered under this whistleblowing policy include:

  • Activities (including those in our programs, at our events, related to our publications, or in our services or those involving our members) that are not in line with SETAC policies
  • Incorrect financial reporting
  • Unlawful activity
  • Personnel (staff)

Provisions

Good Faith Allegation – Anyone raising a concern must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

Harassment or Victimization – Harassment or victimization for reporting concerns under this policy will not be tolerated.

Confidentiality – Every effort will be made to treat the identity of the individual who reported the concern in good faith with appropriate regard for confidentiality to the extent possible, consistent with the need to conduct an adequate investigation.

Anonymous Allegations – This policy encourages individuals to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately, but consideration will be given to:

  • The seriousness of the issue raised
  • The credibility of the concern
  • The likelihood of confirming the allegation from attributable sources

Bad Faith Allegations – Allegations made in bad faith or done maliciously, recklessly or with knowledge of their falsity, may result in disciplinary action.

Compliance Officers

The SETAC executive directors are responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The executive directors will do that by working with a committee of responsible persons consistent with SETAC’s problem resolution procedures. They will advise relevant governance bodies of all complaints and their resolution and will report at least annually to the Executive Committee on compliance activity relating to accounting or alleged financial improprieties.

Procedures

Reporting – Concerns can be reported verbally or in writing through the following channels: 

  • Any concerns can be reported directly to the SETAC compliance officers, the executive directors, verbally or via email at [email protected]
  • Concerns related to the executive directors should be reported to the relevant SETAC president or vice versa
  • Concerns related to very serious and sensitive issues relating to unethical or illegal conduct in financial reporting may be reported directly to William McEachern, Esquire of McDonald Fleming Moorhead (attorneys for SETAC); (850) 602-9344; 127 Palafox Place, Suite 200, Pensacola, FL 32502; [email protected]

Immediately after a concern is raised, it should be recorded by a compliance officer using the SETAC incident eporting form.

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

Evidence – Although the person raising the concern is not expected to prove the truth of an allegation, the person should be able to demonstrate that the report is being made in good faith with reasonable grounds for believing the information disclosed indicates a violation.

Resolution – As soon as an issue is reported, SETAC will take appropriate action following the SETAC problem resolution procedures.

Initial Inquiries – The appropriate compliance officers will conduct initial inquiries to determine whether an investigation is appropriate and the form that it should take. Some concerns may be resolved without the need for investigation.

Further Information – The amount of contact between the complainant and the person or persons investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from or provided to the person reporting the concern.

Closure – The person reporting a concern as well as the relevant SETAC governance executive committee shall receive information on each report of concern and its resolution. Records will be kept by the SETAC office.

Approved by the SETAC World Council on 18 August 2021.