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Whistleblower Policy

Last Updated and Effective: September 4, 2026

1. Purpose and Ethical Standards

The Healthcare Industry Resilience Collaborative, Association (“HIRC”) is committed to the highest standards of ethical, legal, and professional conduct. All directors, officers, advisory council members, employees, contractors, and grantees (collectively, “Stakeholders”) are expected to act with honesty and integrity and to comply with all applicable laws and regulations (the “Ethical Code”).

2. Duty to Report

All Stakeholders are responsible for complying with the Ethical Code and for reporting violations or suspected violations in accordance with this policy.

3. Protection Against Retaliation

HIRC strictly prohibits retaliation against any individual who, in good faith, reports a suspected or actual violation of the Ethical Code. No Stakeholder shall suffer harassment, retaliation, or adverse employment, contractual, reputational, or financial consequences for making a good-faith report.

An employee or contractor who retaliates against someone who has reported a violation in good faith is subject to disciplinary action, up to and including termination of employment or the contract relationship.

This policy encourages internal reporting and resolution of concerns but does not require internal reporting before an individual makes a report to a governmental agency or otherwise makes a disclosure protected by applicable law.

4. Reporting Procedures

HIRC maintains an open-door reporting environment and encourages Stakeholders to raise concerns as early as possible.

  1. Employees should ordinarily report concerns to their supervisor. If they are uncomfortable doing so or are dissatisfied with the response, they may report directly to the Board Chair, Chair Elect, or another member of management.
  2. Supervisors and managers are required to report suspected violations to the Board Chair or Chair Elect.
  3. Contractors and grantees should report concerns directly to the Board Chair or Chair Elect.
  4. Directors and advisory council members should report concerns regarding any Stakeholder to the Board Chair, Chair Elect, or a member of the Executive Committee.
  5. Any individual who is not comfortable using these channels may report concerns directly to a member of the Executive Committee.

5. Investigation and Oversight

The Board Chair and Chair Elect are responsible for receiving and resolving all complaints under this policy and have specific and exclusive responsibility for investigating reported violations. They have direct access to the Executive Committee and shall report at least annually to the Executive Committee regarding whistleblower activity and compliance.

If a complaint concerns the Board Chair or Chair Elect, that individual shall not investigate or resolve the complaint. The other officer shall perform those responsibilities. If both are implicated, the disinterested members of the Board of Directors shall designate an independent person to investigate and shall determine the appropriate resolution.

6. Good-Faith Reporting Requirement

Reports must be made in good faith and based on a reasonable belief that a violation has occurred or may occur. Allegations that are unsubstantiated and made maliciously or knowingly to be false constitute a serious violation of this policy and may result in disciplinary action, up to and including termination.

7. Confidentiality

All reports will be handled confidentially to the extent reasonably possible, consistent with the need to conduct a thorough and fair investigation and to comply with legal obligations.

8. Response and Corrective Action

The Board Chair or Chair Elect will acknowledge receipt of a report within three (3) business days. Reports will be investigated promptly, and appropriate corrective action will be taken by the Board of Directors if warranted.