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Praxis Spinal Cord Institute strives to achieve the highest standards of ethical and legal conduct.
While Praxis’ internal controls are intended to prevent or detect improper activities, even the best systems and internal controls cannot provide absolute safeguards.
Praxis encourages the reporting of suspected or known illegal and inappropriate conduct by Praxis personnel or its partners that affects others (e.g., the SCI community, Praxis personnel, the general public, or Praxis’ own reputation).
Praxis is committed to respect and protect whistleblowers, including their identity to the extent permitted by law, and retaliation against any suspected whistleblower, their colleagues or relatives.
Praxis Spinal Cord Institute has the following whistleblower procedures in place for third parties (e.g., grantees and service providers) and the general public.
When to Report?
Concerns about illegal or inappropriate conduct that affects others should be reported as soon as you have a reasonable suspicion. This allows the concerns to be investigated and addressed promptly.
You are not expected to investigate the matter yourself or to prove that your concern about illegal or inappropriate conduct is well-founded.
If you raise a genuine concern and act in good faith, even if it is later discovered that you are mistaken, under this policy you will not be at risk suffering any form of retribution as a result. This assurance will not be extended to an individual who maliciously raises a matter they know to be untrue or who is involved in any way in the malpractice.
How to Report?
If you wish to report a concern about illegal or inappropriate conduct by Praxis or its partners that affects others, Praxis encourages you to fill out Praxis’ Whistleblower Report Form (.docx, 112KB) and send it to the Chair of the Audit and Finance Committee.
This can be done:
- via email to email@example.com (this email account is only accessible to the Chair of the Audit and Finance Committee and not to any Praxis personnel); or
- by mail (or other means of delivery), addressed to Praxis, in a sealed envelope marked “Private and Strictly Confidential – Attention: Chair of the Audit and Finance Committee of Praxis”, and with the reference “Whistleblowing” on the letter. (Envelope shall be forwarded unopened to the Chair of the Audit and Finance Committee.)
- Your name will not be revealed without your consent to the extent permitted by law (e.g., if an investigation leads to a criminal prosecution, it may become necessary for you to provide evidence or be interviewed by the police). Efforts will be made to treat a report of illegal or inappropriate conduct as confidential, consistent with the need to investigate and prevent or correct the wrongdoing.
- Although Praxis provides the opportunity for the whistleblower to remain anonymous, anonymous reports are very difficult to act upon as there may be little or no corroborated evidence to substantiate the allegations. Proper investigation may prove impossible if the investigator cannot obtain further information from you, give you feedback or ascertain whether your report was made in good faith. Therefore Praxis encourages individuals to come forward with their concerns without remaining anonymous. However, Praxis would rather you report anonymously than keep the information to yourself.
- The whistleblower policy is not meant for personal complaints or grievances (which stems from you being poorly treated and seeking personal redress; there is no additional public interest dimension) and privacy concerns or complaints about Praxis’ information handling practices.
Hence, wrongdoings reported under this policy but that fall under other Praxis policies and procedures, will be typically investigated under those specific policies and procedures. However, if these other established Praxis reporting mechanisms do not result in an acceptable outcome or in cases where the whistleblower policy method is deemed to be the most appropriate for raising wrongdoing, this policy may be used.
Most investigations will be conducted by the Chair of the Audit and Finance Committee with the assistance and direction of whomever he/she thinks appropriate. Persons implicated in the report will not investigate reports in which they have been named.
Some concerns might be based on a misapprehension which can be addressed without delay, some may require urgent investigation, while others could be akin to a tip-off which can be better addressed as part of a forthcoming audit or review.
In complex or sensitive situations, an external investigator might be hired.
Feedback to Whistleblowers
The Chair of the Audit and Finance Committee will acknowledge receipt to whistleblowers within five business days and will advise whistleblowers of the outcome of an investigation. This will not be possible for anonymously submitted reports.
Possible outcomes of an investigation could be that:
- the allegation could not be substantiated; or
- appropriate corrective actions are (to be) made to ensure that the problem does not arise again.
Whistleblowers will not, however, be given details about the actions taken as this could breach the human rights of the person(s) involved.
Appropriate corrective actions will be taken within a reasonable time frame.
Reports to the CEO and Audit and Finance Committee
A summary of whistleblowing reports (in which no personal information is revealed) will be made at least annually by the Chair of the Audit and Finance Committee to the CEO and the Audit and Finance Committee. However important issues will be escalated immediately to the CEO, Audit and Finance Committee and/or Chair of the Board.