WORKING TOGETHER TO PROTECT OUR UNION ETHICS AND COMPLIANCE INITIATIVE (844) NORTHEAST REGIONAL COUNCIL OF CARPENTERS

Transcription

1 (844) NORTHEAST REGIONAL COUNCIL OF CARPENTERS ETHICS AND COMPLIANCE INITIATIVE WORKING TOGETHER TO PROTECT OUR UNION

2 A MESSAGE FROM JOHN BALLANTYNE, EXECUTIVE SECRETARY-TREASURER Dear Brothers and Sisters, I am pleased to inform you of the Northeast Regional Council of Carpenters (NRCC) Ethics and Compliance Initiative. Fraud and corruption in the construction industry can have a devastating impact on our Union and our members. As the NRCC s membership and geographic area grows, it becomes more difficult for full-time Union leadership to be aware of all conduct on hundreds of job sites and in all Locals. We need your help. As a member of the United Brotherhood of Carpenters and Joiners of America (UBCJA), you have an opportunity to make a positive difference by reporting illegal, criminal and unethical conduct as well as major violations of our Constitution and By-Laws that harm our Union and our reputation. Illegal activity on the job site and in the Union environment can take many forms. It can result in lost work opportunities, wage underpayments, tax avoidance by contractors, unsafe working conditions, depletion of our benefit funds, misappropriation of members resources, inadequate representation for members, bribery, coercion of Union officials or members and the infiltration of organized crime. It is the responsibility of each of us to protect our Union, to take a stand and report wrongdoing. I am requesting your assistance in keeping our Union true to its founding principles and in rooting out corruption so that we remain a strong and effective advocate for our 40,000 hardworking members. Fraternally, John Ballantyne Executive Secretary-Treasurer

3 REPORTING ILLEGAL & UNETHICAL ACTIVITY The Northeast Regional Council of Carpenters has established a toll-free hotline to report illegal & unethical activity. You can report anonymously or you may choose to leave your name and contact information. Call in Process: All calls are reported through NAVEX GLOBAL COMPLIANCE, a trusted compliance company serving 12,500 organizations. NAVEX has systems in place to guarantee your confidentiality. Calls are answered by independent advisory team members who have served as ethics or compliance officers. Calls are answered from anywhere, in any language, on a 24 hour 7-day basis. You can also report the complaint online at: Before you call, have the following information: Specific Nature of the Complaint Date of Complaint Company or Employee Name Job site or Location Type of work being performed and when Names of other people aware of the issue Shop Steward or Council Representative involved Callers will be given a case docket number and may check back as to the status of the case. Leaving your contact information will facilitate the investigative process. Documentation of Complaint: Once a call or online report is received and docketed, the case is then assigned to an independent external investigator. Investigators are highly trained and experienced attorneys or former law enforcement personnel. Referral process: Depending on the nature of the complaint, the external investigators will either: Refer the complaint to the NRCC Compliance Taskforce for additional investigation Retain the complaint for formal investigation and review by the Internal Compliance Committee Refer the complaint to Human Resources Dismiss the complaint, if there is insufficient information, or if the complaint is frivolous in nature Investigation Process: Investigators may summon members/employees for interviews, examine documents, conduct audits and interview contractors and Union officials as part of their due diligence. NRCC members must respond to inquiries and to summonses. Investigators will have free reign to root out corruption and wrongdoing. Findings: Once an investigation is completed, a written report will be issued and corrective action will be prescribed. Corrective action may include things like contractors paying the correct wage and benefit payments, restitution to the Funds and reports to Federal/State authorities. Remedies may encompass civil lawsuits or internal charges. The goal is to stop the illegal conduct and make the Union whole.

4 WHAT TYPE OF CONDUCT CONSTITUTES A VIOLATION? These are some examples of what could be considered an illegal or unethical activity: Improper wage payments 1099 workers-misclassification Non-Union workers working on a Union job Contractors not paying workers compensation Contractors paying cash payments to workers Underpayments to our Funds Misapplication of Union resources False Shop Steward reports Failure to protect members from violations of the collective bargaining agreement Self-dealing by Union officials Threats of violence by contractors or agents of contractors Violations of the UBC Constitution or By-Laws Improprieties relating to our Funds WHAT ISSUES ARE NOT APPROPRIATE FOR THE HOTLINE? The hotline is designed to respond to fraudulent, illegal and/or unethical conduct. Do not call for routine information requests. Some issues are more appropriately directed to your Shop Steward or Council Representative. These examples include: Requests for information Routine contract violations Work rule violations Problems with your health benefits, annuity or pension Disagreements between employees or with management The lack of water or facilities on a job site Problems with contract terms and conditions of employment Questions or complaints about the MUP, MAP or Mix 20/20 system

5 FREQUENTLY ASKED QUESTIONS Q. Why should I get involved? A. As a member of the UBCJA, you have a special obligation to work for the greater good, protect our trade and help ensure that your Union brothers and sisters are treated in a fair and equitable manner. Q. How can I be sure that I will not be retaliated against if I make a report? A. The NRCC has a whistleblower protection policy that will safeguard your rights. However, if you still feel ambivalent about filing a complaint, you can do so with total anonymity. Q. How do I know the report will be taken seriously? A. Each complaint will be logged into NAVEX Global, a professional service designed to document all calls or online filings. Every complaint will be forwarded to a trained external investigator who will carefully review the issue against external law and internal Union Constitution and By-Laws. Q. How long does it take to investigate an issue? A. That will depend on the complexity of the case. All complaints will receive the prompt attention of an external investigator. Q. How will I know if action is taken? A. Each complaint is given a file number and you can check back online on the status of the complaint.

6 HOW THE COMPLIANCE SYSTEM WORKS STEP 1 Call placed to (844) STEP 2 Call is categorized by NAVEX Global STEP 3 Complaint forwarded to external investigator for initial review STEP 4A STEP 4B STEP 4C Matter referred to Compliance Task Force (CTF). Findings and recommendations forwarded to external investigator for review Matter referred to Human Resources Dept. Findings and recommendations forwarded to external investigator for review Matter retained for investigation by external investigator. Notice to Internal Compliance Committee (ICC) of either immediate resolution or request for authorization to proceed STEP 5 STEP 6 Findings and recommendations from Steps 4A, 4B, and, if authorized, 4C reviewed with ICC ICC Decision: determine action. NRCC leadership informed of results HAVE THIS INFORMATION READY WHEN CALLING OR FILING YOUR REPORT ONLINE: What is your complaint? be specific What is the location? Contractor s name if applicable Time of violation How did you become aware of the violation? Names of others aware of issue Has Shop Steward been notified? Has Union Hall been notified?

7

8 ETHICS AND COMPLIANCE INITIATIVE NORTHEAST REGIONAL COUNCIL OF CARPENTERS (844)