HomeMy WebLinkAbout08. Adopt proposed new Board Policy No. BP 034-Reporting Protocol for Ethics Hotline Page 1 of 5
Item 8.
CENTRAL SAN BOARD OF DIRECTORS
' POSITION PAPER
MEETING DATE: JUNE 7, 2018
SUBJECT: ADOPT PROPOSED NEW BOARD POLICY NO. BP 034 - REPORTING
PROTOCOL FOR ETHICS HOTLINE
SUBMITTED BY: INITIATING DEPARTMENT:
KATIE YOUNG, SECRETARY OF THE SECRETARYOF THE DISTRICT
DISTRICT
REVIEWED BY: TEJI O'MALLEY HUMAN RESOURCES MANAGER
PHIL LEIBER, DIRECTOR OF FINANCE AND ADMINISTRATION
ANN SASAKI, DEPUTY GENERAL MANAGER
Roger S. Bailey
General Manager
ISSUE
Board approval is required for adoption of new Board Policies.
BACKGROUND
During 2018, several internal audits have been conducted by Central San's temporary internal auditor. One
of the audits focused on the internal control environment at Central San and the reporting mechanisms
available to employees and Board Members who may become aware of potential wrongdoing. Good
practice is that employees be provided a way to anonymously report issues, apart from going through their chain
of command, in which the potential fear of recrimination is possible.
It was suggested by the internal auditor that a Board Policy be adopted for reporting mechanisms for processing
anonymous information received from employees via a third-party hotline service for reporting potential fraud or
misconduct. The California Sanitation Risk Management Authority (CSRMA) offers such a hotline (WeTip) to
its pool membership at no additional charge. Central San is a member of CSRMA.
June 7, 2018 Regular Board Meeting Agenda Packet- Page 76 of 446
Page 2 of 5
Attached for the Board's consideration is a proposed new Board Policy No. BP 034 - Reporting Protocol
for Ethics Hotline. Also attached are the draft associated Administrative Procedures (AP 034) being
developed to address the protocol for employees and Board Members. The Board does not typically
review or approve administrative procedures; however, since these procedures will apply to the Board
Members as well as employees, they are being presented for review and information.
ALTERNATIVES/CONSIDERATIONS
The Board may choose not to adopt the proposed policy, or may provide other direction to staff.
FINANCIAL IMPACTS
None.
COMMITTEE RECOMMENDATION
The Administration Committee reviewed both BP 034 and AP 034 at its May 8, 2018 meeting. It was the
consensus of the Committee to recommend that the proposed policy and associated administrative
procedures be changed to reflect that the Secretary of the District should report all calls to both the internal
auditor and General Manager as appropriate. Both documents presented with this Position Paper have
been modified in accordance with the Committee's recommendation.
RECOMMENDED BOARD ACTION
Adopt new Board Policy No. BP 034 - Reporting Protocol for Ethics Hotline.
ATTACHMENTS:
1. Draft BP- 034 Reporting Protocols for Ethics Hotline
2. Draft AP - 034 Reporting Protocols for Ethics Hotline
June 7, 2018 Regular Board Meeting Agenda Packet- Page 77 of 446
Page 3 of 5
Number: BP 034
Related Admin. Procedure: AP 034
Authority: Board of Directors
Effective: CENTRALSAN
Revised: CENTRALSAMORG
Reviewed:
Initiating Dept./Div.: Administration/SOD
BOARD POLICY
REPORTING PROTOCOL FOR ETHICS HOTLINE
PURPOSE
To establish a policy on reporting mechanisms for processing anonymous information
received from employees via a third-party hotline service for reporting potential fraud or
misconduct.
POLICY
The Board of Directors supports making available to employees and Board Members
the opportunity to anonymously report any potential fraud or misconduct at Central San.
The reporting avenue shall preserve anonymity and be separate from Central San
management's normal reporting structure to prevent any potential barriers to the
reporting of potential wrongdoing.
Should the employee not wish to be anonymous, the employee shall be protected from
retaliation.
The Secretary of the District's office shall be responsible for cataloging and reporting
information received via the hotline service to the General Manager, Internal Auditor,
Deputy General Manager, District Counsel, and Department Directors as appropriate.
[Original retained by the Secretary of the District]
June 7, 2018 Regular Board Meeting Agenda Packet- Page 78 of 446
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Number: AP 034
Authority: BP 034
Effective: —
Revised:
Reviewed: CENTRALSAN -
Date
Initiating Dept/Div: Administration/SOD Signed: CENTRALSAMORG
Katie Young, Secretary of the District
Roger S. Bailey, General Manager
ADMINISTRATIVE PROCEDURE
REPORTING PROTOCOL FOR ETHICS HOTLINE
1. PURPOSE
To set forth an Administrative Procedure for the Secretary of District on the
reporting protocol for anonymous information received from employees and/or
Board Members via the third-party Ethics Hotline (WeTip).
2. PROCEDURE/GUIDELINES
a. Information about the Ethics Hotline will be provided in the Employee Handbook
notifying employees of the ethics reporting service. Specific contact information,
etc. can be found on bulletin boards throughout the District.
b. When the Secretary of the District receives a report form the third-party service
"WeTip", the Secretary of the District will catalog the item (incoming date, brief
description and status (open, closed etc.)) on a log.
c. Should the Secretary of the District be absent, the Assistant to the Secretary of
the District will catalog the report.
d. Incoming tips will generally be routed from the Secretary of the District to the
Internal Auditor and General Manager for future assignment of investigation and
subsequent follow-up. If the matter involves a Board Member, Department
Director or the Deputy General Manager, it will be directly routed to the General
Manager. If the matter involves the General Manager, it will be directly routed to
the Board President.
e. Reports from "WeTip" will be directed through the District Counsel when deemed
appropriate.
June 7, 2018 Regular Board Meeting Agenda Packet- Page 79 of 446
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Number: AP 034
REPORTING PROTOCOLS FOR ETHICS HOTLINE
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f. At his discretion, the General Manager will inform the Board of Directors of any
ongoing tips or investigations.
[Original retained by the Secretary of the District]
June 7, 2018 Regular Board Meeting Agenda Packet- Page 80 of 446