HomeMy WebLinkAbout3.c. Review Draft Position Paper to Adopt Proposed New Board Policy No. BP 034- Reporting Protocol for Ethics Hotline Page 1 of 5
Item 3.c.
CENTRAL SAN BOARD OF DIRECTORS
POSITION PAPER
DRAFT
MEETING DATE: MAY 8, 2018
SUBJECT: REVIEW DRAFT POSITION PAPER TO ADOPT PROPOSED NEW BOARD
POLICY NO. BP 034 - REPORTING PROTOCOL FOR ETHICS HOTLINE
SUBMITTED BY: INITIATING DEPARTMENT:
KATIE YOUNG, SECRETARY OF THE SECRETARY OF THE DISTRICT
DISTRICT
REVIEWED BY: TEJI O'MALLEY, HUMAN RESOURCES MANAGER
PHIL LEIBER, DIRECTOR OF FINANCE AND ADMINISTRATION
ANN SASAKI, DEPUTY 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 new 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
that a Board Policy be adopted for reporting mechanisms for processing anonymous information received
from employees via athird-party hotline service for reporting potential fraud or misconduct.Attached is a
proposed new Board Policy No. BP 034 - Reporting Protocol for Ethics Hotline.
Also attached is 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.
May 8, 2018 Regular ADMIN Committee Meeting Agenda Packet- Page 14 of 41
Page 2 of 5
ALT ERNAT IVES/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. The
Committee recommended Board approval of proposed B P 034 and had no comment with respect to the
proposed administrative procedures.
RECOMMENDED BOARD ACTION
Adopt new Board Policy No. B P 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
May 8, 2018 Regular ADMIN Committee Meeting Agenda Packet- Page 15 of 41
Page 3 of 5
Central Contra Costa
Number: BP 034 San1�U'�'�,/District
Related Admin. Procedure: AP 034
Authority: Board of Directors
Effective:
Revised:
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 athird-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, Deputy General
Manager, District Counsel, and Department Directors as appropriate.
(Original retained by the Secretary of the District)
May 8, 2018 Regular ADMIN Committee Meeting Agenda Packet- Page 16 of 41
Page 4 of 5
Number: AP 034
Authority: BP 034
Effective: —
Revised:
Reviewed: CENTRAL
Initiating Dept/Div: Administration/SOD
Date 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
Executive Team (General Manager, Deputy General Manager and Department
Directors) 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.
May 8, 2018 Regular ADMIN Committee Meeting Agenda Packet- Page 17 of 41
Page 5of5
Number: AP 034
REPORTING PROTOCOLS FOR ETHICS HOTLINE
Page 2of2
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]
May 8, 2018 Regular ADMIN Committee Meeting Agenda Packet- Page 18 of 41