Whistleblower Policy

2-12

UCAR is committed to high standards of ethical and legal conduct, including adhering to all laws and regulations that apply to UCAR. The support of all employees is necessary to achieve an ethical work environment. The purpose of this policy is to reaffirm UCAR's commitment to open communications and providing employees with a means to raise concerns and reassurance that they will be free from retaliation for doing so.

UCAR will not retaliate against an employee who, in good faith, raises a legitimate complaint against UCAR or any UCAR employee with regard to an unethical activity, questionable accounting or financial practice, or violation of law, regulation or policy. Persons found to have engaged in retaliation as a result of concerns being raised are subject to the full range of disciplinary actions, including termination. UCAR employees may access any of the following options for reporting such concerns:

• Anonymously, through the UCAR Ethics web site
• Immediate supervisor or any member of UCAR/UCP/NCAR management
• Human Resources
• Ethics Officer

Complaints brought in bad faith or for which an employee has provided false information, may result in disciplinary action, including termination.

The Vice President for Finance and Administration is responsible for interpretation of this policy.

See also: Policy Administration 1-2; Research Misconduct 2-5; Workplace Conduct 2-6; Sexual Harassment 2-7; Anti-Fraud 2-8; and the Problem Resolution Policy 6-8.

Whistleblower Procedures

(related to Policy 2-12)

2-12

1.  Reporting. This whistleblower procedure is intended to be used for serious and sensitive issues. The earlier a concern is raised, the easier it is to take action. Serious concerns relating to questionable financial and accounting practices, unethical activity or violations of law, regulation or policy should be reported through any of the options set forth in the policy. Concerns expressed anonymously will be explored appropriately, but considerations will be given to the seriousness of the issue raised, the credibility of the concern, and the ability to confirm the allegation. While not required, it can be most helpful if the employee can identify him/herself so that UCAR can best explore the concern. (See confidentiality, below.) Concerns related to human relations issues should continue to be resolved as set forth in the Problem Resolution Policy 6-8.

2.  Treatment of Complaints. The actions taken by UCAR in response to a complaint under this Policy will depend on the nature of the complaint. Upon receipt of a complaint, UCAR will determine whether an investigation is appropriate, and the form it should take. Some concerns may be resolved without the need for an investigation. Depending on the concern, different internal or external people may be involved, up to and including the UCAR General Counsel, President's Council, the UCAR Board of Trustees, or federal agency Inspectors General. The amount of contact between the complainant and the person(s) conducting the investigations will depend on the nature of the issue and the information needed.

3.  Confidentiality. Every effort will be made to treat the information, including the identity of the complainant, confidential. However, consistent with the need to conduct a thorough investigation, complete confidentiality cannot be guaranteed. Follow-up by the person(s) conducting the investigation may involve discussions with the complainant and aspects of the complaint may become more broadly known as part of an investigation. Under some circumstances, further disclosure by UCAR to federal agency personnel or inspector generals, or law enforcement may also be required.

4.  Retaliation. Any claims of retaliation for making a complaint under this Policy should be reported directly to the Director of Human Resources.