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Definition of Misconduct, Dishonesty and Fraud

 For purposes of this policy, misconduct, dishonesty and fraud include but are not limited to:

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• Damage to the body of Christ and to the reputation of the body of Christ
• Damage to the reputation of Reliant and its employees
• Negative Publicity
• Actual financial loss
• Investigation costs
• Loss of employees
• Loss of donors
• Damaged relationships with donors and friends of the ministry
• Damaged employee morale
• Litigation

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Reliant's Commitment

Reliant's goal is to establish and maintain a business environment of fairness, ethics and honesty for our employees, our donors, our constituents, our suppliers, and anyone else with whom we have a relationship

Reliant is also committed to the deterrence, detection and correction of misconduct and dishonesty. The discovery, reporting and documentation of such acts provides a foundation for the protection of innocent parties, the taking of disciplinary action against offenders up to and including dismissal where appropriate, the referral to law enforcement agencies when warranted by the facts, and the recovery of assets.

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Additional Responsibilities of Supervisors

 All employees have a responsibility to report suspected violations. However, employees with supervisory and review responsibilities at any level have additional deterrence and detection duties. Specifically, personnel with supervisory or review authority have these three additional responsibilities:

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Assistance in effectively carrying out these responsibilities is available upon request through the Director of Organizational Affairs.

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Safeguards

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No Retaliation

No director, officer, or employee 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, or is a violation of state or federal law.

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Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations, including the complainant's identity, will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. All documentation related to reported violations and investigations of such reports shall be maintained in confidential files, with access permitted only on a need-to-know basis or as required by law.

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Anonymous Allegations

This policy encourages employees to put their names to allegation because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, 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

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Acting in Good Faith

Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates misconduct, dishonesty, or fraud. Any allegations that prove not to be substantiated and which it is determined have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

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Procedure:

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How to raise a concern

It is the responsibility of every Reliant employee to report concerns relating to suspected misconduct, dishonesty or fraud. You should first raise your concern with your immediate supervisor or manager who, in accordance with Reliant's policies and procedures, will assist you with resolving the concern or reporting it to the next level. If your concern involves your immediate supervisor or manager, please raise your concern directly with the Director of Organizational Affairs. If your concern involves an executive level employee, you may address your concern directly to the Chairman of the Audit Review Committee. Concerns should normally be set forth in writing with as much information as possible, including any relevant names, dates, places, etc.

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809 South 3rd St.

Philadelphia, FA 19147

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Investigating the Concern

Following the receipt of any complaints submitted, an Investigative Team (led by the Director of Organizational Affairs) will investigate each matter so reported and where appropriate, recommend corrective and disciplinary actions to the Executive Director. Complaints that the Investigative Team determines are of special concern, or that involve executive level employees, will be referred to the Chairman of the Audit Review Committee for investigation. If investigated by the Audit Review Committee, the Committee may enlist Committee members, employees of the ministry and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding financial reporting, accounting, internal accounting controls, auditing matters, or any other form of misconduct, dishonesty, or fraud. In conducting any investigation, the Audit Review Committee shall use reasonable efforts to protect the confidentiality and anonymity of the complainant. The Committee will determine the proper method of recommending and/or taking corrective and disciplinary actions, where appropriate.

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Further Information

The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the complainant.

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Report to Complainant

The complainant will generally be given the opportunity to receive follow-up on their concern within two weeks, which may include:

• 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
• Telling them whether further investigations will follow, and if not, why

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Information

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