Whistleblower Policy

The International Federation of Clinical Neurophysiology (IFCN) requires its members, participants in IFCN activities, and management staff to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities on behalf of the IFCN. As representatives of the IFCN, IFCN member societies and ISNC members must carry out their duties and responsibilities with integrity and comply with all applicable laws and regulations. This Policy sets forth the processes by which IFCN member societies and ISNC members outlined above may report potential unethical conduct in the context of IFCN-related functions.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable all IFCN members, participants in IFCN activities, and management staff to raise serious concerns so that the IFCN can address inappropriate, unethical, or illegal conduct and actions. It is the responsibility of all those associated with the IFCN, including volunteers, participants in IFCN activities, and management staff to report concerns about violations or suspected violations of law or regulations that govern and apply to IFCN’s governance, finances, and operations.

No Retaliation

It is contrary to the values and policies of the IFCN to retaliate against an IFCN member society, ISNC member or management staff member who in good faith reports a potential violation of law, including complaints of discrimination, harassment, fraud, or regulations governing IFCN operations. An IFCN member society, ISNC member or management staff member who retaliates against someone who has reported a violation in good faith will be subject to discipline, up to and including termination of employment in the case of management staff.

Reporting Procedure

The IFCN leadership and its management company have an open-door policy and encourage IFCN member societies, participants in IFCN activities, and management staff to share their questions or concerns, suggestions, or complaints. This information can be shared either in person or in writing with either the IFCN Executive Director, the management company Human Resources Director (in the case of personnel issues), or to the IFCN Executive Director or IFCN Treasurer in the case of financial or management concerns. In the event of concerns or a complaint addressed to quality of service or misuse of IFCN property, such complaint should be directed to the IFCN President. All reported complaints will be investigated.

In addition to the above-described reporting procedures, the following IFCN Whistleblower Protection message is located at the bottom of the IFCN website homepage:

To anonymously report suspected criminal activity or illegal or unethical conduct by an IFCN member, management staff, or participant in any IFCN activity or IFCN business relationship, call the Navex toll-free fraud hotline:

US/Canada toll-free: +1.800.826.6762. 
For individuals outside the US and Canada please use the following two-step dialing process:

1. Dial the AT&T Direct Access Code
2. Dial +1.800.826.6762

Callers should expect to hear an English greeting and to speak to an English-speaking agent.

 

Compliance Officer

The IFCN’s Executive Director is primarily charged with carrying out this policy and is responsible for ensuring that all complaints about illegal conduct are investigated and resolved. The Executive Director will advise the IFCN Executive Committee of all complaints and their resolution and report at least annually to the IFCN Executive Committee, including the Treasurer on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

The IFCN’s Executive Director shall immediately notify the Treasurer and IFCN Executive Committee of any concerns or complaint regarding corporate accounting practices, internal controls, or auditing and work with the same until the matter is resolved.

Acting in Good Faith

Any person making a complaint, orally or in writing, concerning a potential violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously, recklessly, or knowingly to be false will be viewed as a serious disciplinary offense and addressed by the Executive Committee. In the case of IFCN’s management company staff, the making of a malicious or knowingly false report may result in disciplinary action, up to and including termination of employment.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The IFCN’s Executive Director will notify the person who submitted the complaint and acknowledge receipt of the reported potential violation. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.