Panthera’s Whistleblower policy is intended to encourage and enable employees and others to raise serious concerns internally so that Panthera can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Panthera’s Code of Ethics or suspected violations of law or regulations that govern Panthera’s operations. Whistleblowers are not responsible for investigating the activity or for determining fault or corrective measures. The CEO or Head of Human Resources is charged with these responsibilities.
If an employee has knowledge of or a concern about violations of Panthera’s Code of Ethics or suspected violations of law or regulations, the employee is to contact the CEO or Head of Human Resources. In the event that the employee is not comfortable reporting such information to the foregoing persons, such information can be reported to the Panthera's Board of Directors, or the employee can submit an anonymous complaint via the Panthera Intranet site at https://panthera40.sharepoint.com/. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.
After notification of the employee's complaint, an investigation will be initiated promptly to gather facts about the complaint. The confidentiality of the whistleblower will be maintained to the extent possible. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. After the investigation has been completed Panthera will make a determination regarding the resolution of the case, and will take corrective and/or disciplinary action as appropriate.
Panthera will not tolerate retaliation by management, employees or co-workers against employees for filing a complaint or participating in any manner in an investigation, proceeding, or hearing related to a complaint. Any whistleblower who believes they are being retaliated against must contact the CEO or the Head of Human Resources immediately, or if the employee is not comfortable reporting to the foregoing persons, such information can be reported to the Panthera's Board of Directors. Protection against retaliation does not include immunity for any personal wrongdoing or violation of company policies. If Panthera determines a violation of this policy has occurred, appropriate disciplinary action, up to and including termination, will be taken.
Panthera will comply with all laws affecting its activities including federal, state and local laws relating to record retention and document destruction.
Panthera will maintain a back-up for all electronic communications for a period of 3 years. The back-up is stored off site.
Panthera will maintain financial and personnel records in current use in accessible and labeled file cabinets on site. File cabinets and confidential records will be locked at the end of each business day.
Panthera will maintain historical financial and personnel records in secured file cabinets or in boxes that are clearly labeled. These will be maintained on site to the degree our space allows.
The Audit Committee of Panthera Board of Directors oversees the financial recordkeeping policy.
At the expiration of the retention period, to the degree practicable, hard copy files will be shredded and electronic records will be erased or destroyed and no longer retained by any company employee in a retrievable form.
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© Sebastian Kennerknecht
