PURPOSE The purpose of this Whistleblower Policy is to encourage current and former employees, volunteers and Board members to communicate events of serious concerns about the Association.
The Automotive Industries Association of Canada (AIA) is committed to conducting itself with honesty and integrity at all times. If, at any time, this commitment is not followed or appears in doubt, AIA will seek to identify and remedy such situations. Accordingly, it is the Policy of AIA to ensure that when an individual has reasonable grounds to believe that an AIA employee, volunteer or board member has committed, or is about to commit, an AIA whistleblowing event:
- The employee, volunteer or board member may disclose this information
- The complainant will be protected from reprisals;
- All parties to an investigation will be treated fairly and equitability;
- Confidentiality will be maintained to the greatest extent possible;
- If wrongdoing is found, appropriate remedial and disciplinary actions will be taken.
This Policy is in accordance with Federal and Provincial Legislation and is located on the AIA Website: https://www.aiacanada.com/whistleblower-policy/
DEFINITION – REASONABLE GROUNDS OF A “WHISTLEBLOWER EVENT”
For the purposes of this Policy, a complaint may be submitted if any one of the following incidents occurs:
- Accounting, auditing, or other financial reporting fraud or misrepresentation;
- Violations of federal or provincial laws that could result in fines or civil damages payable by AIA, or that could otherwise significantly harm AIA's reputation or public image;
- Unethical business conduct in violation of any AIA policies and/or AIA Code of Conduct;
- Danger to the health, safety, or well-being of employees, volunteers and/or the general public
A complaint may be submitted in writing to the President, the Chairman of the Board or Chair of the finance and audit committee.
The written statement should include the following information:
- Description of the activity
- Date complainant became aware of the activity
- Name of individual suspected of the activity
- Steps taken (if any) prior to making complaint or allegation (i.e. spoke with supervisor)
- The statement shall be addressed in writing to one, two or all of the three Officers listed below via email or regular mail. The complainant shall expect a confirmation of receipts of the complaint within 5 business days.
- The complainant will not be discharged, demoted, suspended, threatened, harassed, or in any other manner discriminated against as a result of communicating a genuine concern. Any AIA employee found to be in violation of this policy when dealing with a complainant may be subject to termination of employment. Similarly, any volunteer or Board member found to be in violation of this policy when dealing with a complainant may have their relationship with AIA terminated.
- An individual is not required to prove the truth of an allegation, but he/she is required to act in good faith, and to provide sufficient evidence to the person contacted in order to show that there are sufficient grounds for concern. The amount of contact between the complainant and the investigating body will depend on the nature of the issue and the clarity of the information provided. The investigating body may seek further information from the complainant.
- Any individual who does not act in good faith in reporting a suspected violation may be subject to disciplinary action up to and including termination of employment or relationship with AIA.
- All complaint will be treated as confidential and sensitive. In addition, the complainant shall be provided the opportunity to remain anonymous, save and except in those circumstances where the nature of the disclosure and/or the resultant investigation make it necessary to disclose identify (for example, legal investigations or proceedings). In such cases, all reasonable steps shall be taken to protect the complainant from harm as a result of having made a disclosure.
Once a complaint is brought forward an investigation will commence. The Officer in receipt of the complaint may enlist the assistance of other employees, legal counsel, accounting or other advisors as may be appropriate to conduct the investigation. A report will be prepared and any legal or other action will be taken as appropriate. Each complaint will be treated as confidentially as possible and with due care. The results of the investigation will be shared with the complainant to the extent possible and within reasonable time.
This Policy applies to all current and former employees, volunteers and Board members of AIA.
Jean-François Champagne, President
180 Elgin Street, Suite 1400
Ottawa, ON, K2P 2K3
Chairman of the Board
Spectra Premium Industries Inc.
1421 Ampère St.
Boucherville, QC J4B 5Z5