OTA Whistleblower Policy

Oklahoma Telephone Association (OTA) Statement of Ethical Principles (“Statement”) requires members and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Members and employees must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all members and employees to comply with the Statement and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation

No member or employee who, in good faith, reports a violation of the Statement shall suffer harassment, retaliation or adverse consequence. Any member or employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including removal from their respective position in accordance with OTA policies. This Whistleblower Policy is intended to encourage and enable members and employees to raise serious concerns within OTA prior to seeking resolution outside OTA.

Reporting Violations

Members and employees should always share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, any officer is in a position to address any areas of concern. Officers are required to report suspected violations of the Statement of Ethical Principles to the Treasurer, who has specific responsibility to investigate all reported violations. For suspected fraud individuals should contact the Treasurer directly. Should a member or employee be unsatisfied or uncomfortable contacting the Treasurer, the Association President should be contacted.

Compliance Officer

The Treasurer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Statement and, at discretion, shall advise the Executive Vice President and/or the Audit, Budget and Finance committee. The Treasurer is required to report to the Audit, Budget and Finance committee at least annually on compliance activity. Should the Treasurer be out of town for an extended amount of time or otherwise unavailable, the Association President will assume the role of the compliance officer.

Accounting and Auditing Matters

The Audit, Budget and Finance Committee of the Board of Directors shall address all reported concerns or complaints regarding appropriate accounting practices, internal controls or auditing. The Treasurer shall immediately notify the Audit, Budget and Finance Committee of any such complaint and work with the Committee until the matter is resolved.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the Statement must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Statement. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Treasurer will notify the sender and acknowledge receipt of the reported violation or suspected violation in a timely manner. In the case the Treasurer is out of town for an extended amount of time or otherwise unavailable, the Association President will acknowledge the reported violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.