Reporting Compliance Violations
UNISHKA encourages the prompt reporting of compliance violations so that rapid and constructive action can be taken to address the violation and maintain UNISHKA’s integrity. All Personnel have an affirmative duty to report suspected compliance violations or wrongdoing. Should Personnel not report compliance violations of which they have first-hand knowledge, the individual may be subject to discipline or termination and may be held peculiarly responsible for all reasonable losses and damages incurred by the company. Reports of suspected improper or wrongful activity will be treated confidentially, and employees may report compliance violations or wrongdoing anonymously. If submitting an anonymous report, it is imperative to provide sufficient detail regarding the compliance violation or wrongdoing including identification of potential witnesses to enable UNISHKA to effectively address matter.
Guidance for reporting suspected violations or wrongdoing include:
- Individuals who believe they have witnessed compliance violations or wrongdoing should discuss their concerns with their immediate supervisor (documenting the discussion in an email).
- Should the supervisor or manager in the chain of command be suspected of a violation, the individual reporting the violation should report to the Compliance Coordinator or a member of the Executive team.
- Should the Compliance Coordinator be the subject of an allegation, the reporting individual should communicate directly to the President or Corporate Secretary.
- Should the violation include an allegation of criminal conduct, the reporting individual should notify the Compliance Coordinator, President or Corporate Secretary as well as the company’s outside legal counsel.
- Retaliation for good-faith reports of non-compliance or wrongdoing are, themselves, violations and should be reported to the President, Corporate Secretary or outside counsel.
- Retaliation for good-faith reports of non-compliance or wrongdoing may subject the offender to disciplinary action up to and including termination.
- Malicious or intentionally false reports of non-compliance or wrongdoing may subject the offender to disciplinary action up to and including termination.
| Title | Contact |
|---|---|
| Compliance Coordinator | Hilary Coonjohn
(hacoonjohn@unishka.com) |
| President (ex officio) | Jeffrey Coonjohn
(jjcoonjohn@unishka.com) |
| Senior Compliance Consultant
(ex officio) | Kevin Krispin
(kkrispin@unishka.com) |
| Outside Legal Council
(Baxter, Bruce, & Sullivan) | Gabe Sassoon
(gsassoon@bbslawyer.com) |