1. Summary

1.1

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The purpose of this document is to communicate policy regarding the deterrence and investigation of suspected misconduct and

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/or fraud by employees and

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volunteers of Reliant Mission ("Reliant"), and to provide specific instructions regarding

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reporting of suspected violations.

1.2 Reliant is committed to high standards of ethical, moral, and legal conduct. In line with this commitment and also Reliant's commitment to open communication, this policy aims to provide an avenue for employees and volunteers to raise concerns about suspected misconduct

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and/or fraud, and to provide reassurance that they will be protected from reprisals or victimization for good faith

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reporting of same (“whistleblowing”).

2. Definition of Misconduct,

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Fraud, and

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Whistleblowing

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

• Acts which materially violate ministry policy
• Theft or other misappropriation of ministry assets
• Intentional misstatements or other irregularities in ministry records
• Incorrect financial reporting
• Misuse of ministry resources
• Violation of any federal, state, or local law, rule, or regulation
• Immoral or unbiblical Unethical activities
• Forgery or alteration of documents
• Any other form of fraud

The organization 2.2 Reliant specifically prohibits these the above and any other illegal activities in the actions of its employees, managers, executives, and others volunteers responsible for carrying out the organization's organization’s activities. The impact of misconduct , dishonesty and/or fraud may include:

• 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 Publicitypublicity
• Actual financial loss
• Investigation costs
• Loss of employees
• Loss of volunteers
• Loss of donors
• Damaged relationships with donors and friends of the ministry
• Damaged employee morale
• Litigation

Reliant's Commitment

2.3 A whistleblower as defined by this policy is an employee or volunteer of Reliant who reports an activity that he/she believes in good faith to be misconduct and/or fraud as described by this policy. The whistleblower is not responsible for investigating the activity, nor for determining fault or corrective measures; appropriate management officials (or contracted third parties) will be charged with these responsibilities.

3. Reliant’s Commitment

3.1 Reliant’s Reliant's goal is to establish and maintain a business environment of fairness, ethics and honesty fair, ethical, and honest ministry environment for our employees, our volunteers, our donors, our constituents, our suppliers, and anyone else with whom we have a relationship.

3.2 Reliant is also committed to the deterrence, detection, and correction of misconduct and dishonesty/or fraud. 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 from his/her duties with Reliant, where appropriate), the referral to law enforcement agencies when warranted by the facts, and the recovery of assets.

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4. Supervisor’s Responsibilities

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4.1 All employees and volunteers  All employees have a responsibility to report suspected violations of this policy. HoweverFurther, employees and/or volunteers 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, for which assistance and guidance is available upon request through the Director of Organizational Affairs:

• First, you should become aware of what can go wrong in within your area of authority.
• Second, in within your area of authority, you should put into place and maintain monitoring, review, and control procedures which can prevent acts of wrongdoing.
• Third, in within your area of authority, you should put into place and maintain monitoring, review, and control procedures which can promptly detect acts of wrongdoing should prevention efforts fail.

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

Safeguards

No Retaliation

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4.2 Supervisors who receive a complaint under this policy from an employee or volunteer should immediately notify the HR Director via notifyHR@reliant.org or 407-490-0141.

5. No Retaliation

5.1 No employee, volunteer, director, or officer who in good faith reports a suspected violation of this policy shall suffer harassment, retaliation, or adverse employment consequence. An employee who retaliates against someone who has

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made a

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good faith reporting of a suspected violation of this policy is subject to discipline, up to and including

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dismissal from his/her duties for Reliant. Such retaliation is prohibited to encourage and enable employees and

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volunteers to raise concerns within the organization, prior to seeking resolution outside the organization.

5.2 Additionally, no employee shall be adversely affected because they refuse to carry out a directive which

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constitutes

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a violation of state or federal law.

5.3 A “good faith” complaint is one for which the employee or volunteer has reasonable grounds for belief that the act(s) being complained of constitutes misconduct or fraud. Any reports of violation of this policy which prove to be unsubstantiated and which are determined to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

6. Confidentiality

6.1 Violations or suspected violations of this policy may be submitted on a confidential basis by the complainant, or

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submitted anonymously. Reports of violations or suspected violations, including the

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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.

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

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.

Procedure:

How to raise a concern

7. Complaint Procedure

7.1 It is the responsibility of every Reliant employee or volunteer to report concerns relating to suspected misconduct

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and/or fraud.

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Such reports should be first

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raised with the employee’s or volunteer’s immediate supervisor or manager who, in accordance with

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Reliant’s policies and procedures, will assist

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with resolving the concern, or reporting it to the next level. If

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the reporting involves

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the immediate supervisor or manager of the reporting employee or volunteer, or if the reporting party feels he/she cannot direct his/her report to a supervisor or manager,

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the employee/volunteer may report directly to the HR Director or via Reliant’s Employee Reporting Hotline. The reporting employee/volunteer has the option of remaining anonymous when using the Employee Reporting Hotline.

7.2 Reporting options:

• Reporting to HR Director
  • Email notifyHR@reliant.org
  • Call 407-490-0141
• Reporting via the Employee Reporting Hotline 
  • Go to http://www.lighthouse-services.com/reliant
  • Call 844-544-1444
  • Email reports@lighthouse-services.com (indicate that report is for Reliant)
  • Fax: 215-689-3885 (indicate that the report is for Reliant)

7.3 The details of the report should be specific and should include the names of the individuals involved as well as the names of any potential witnesses.

8. Investigating the Concern

8.1 Each submitted complaint will be reviewed. Where appropriate, the matter will be investigated by an Investigative Team which will recommend to the Executive Director any corrective or disciplinary actions.

8.2

Concerns submitted to the Director of Organizational Affairs should be personally delivered to the Reliant office, or sent in a sealed envelope to:

Reliant Director of Organizational Affairs

David Meldrum-Green

11002 Lake Hart Dr. Suite 100

Orlando, FL 32832

Concerns submitted to the Chairman of the Audit Review Committee should be personally sent in a sealed envelop to:

Chairman of the Audit Review Committee

Jim Kaufman

809 South 3rd St.

Philadelphia, FA 19147

Investigating the Concern

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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

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and/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.

Further Information

8.3 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.

9. 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

Information

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9.1 To the extent possible in order to maintain confidentiality, the employee/volunteer will be advised of the resolution of his/her reporting.

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Standards of Conduct

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