Code of Conduct Compliance Policy

Vendor Code of Conduct
IMRF Code of Conduct

Reporting Responsibility

It is the responsibility of all directors and employees to comply with the Code and to report violations or suspected violations in accordance with this Code of Conduct Compliance Policy.

It is also the responsibility of all staff to report to their supervisor, manager, or director, or to the Compliance Officer or the Executive Director, any reasonable suspicion of a false statement or falsified record being submitted or filed with IMRF or permitted to be submitted or filed by any person. A “reasonable suspicion” means a belief, based upon specific and articulable facts, taken together with rational inferences from those facts, that would lead a reasonable person to believe that fraud has been, or will be, committed. A reasonable suspicion is more than a non-particularized suspicion. A mere inconsistency, standing alone, does not give rise to a reasonable suspicion. The person to whom the report is given shall provide a written response to the reporting staff member regarding the action taken because of the report.

Failure to comply with this Policy may result in disciplinary action up to and including termination.

No Retaliation

No employee may be asked or told to violate any laws, rules or regulations as part of their employment at IMRF. No employee who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. Any attempt to deter a co-worker from reporting violations is considered unacceptable conduct and is subject to discipline up to and including termination of employment.

This Code of Conduct Compliance Policy is intended to encourage and enable employees and others to raise serious concerns within IMRF prior to seeking resolution outside IMRF.

Compliance Officer

IMRF’s Compliance Officer is its general counsel and is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at her discretion, shall advise the Executive Director and/or the President of the Board of Trustees.

The Compliance Officer has direct access to the audit committee of the board of trustees and is required to report to the audit committee at least annually on compliance activity.

Accounting and Auditing Matters

The audit committee of the board of trustees shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the audit 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 Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code. Any allegations which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Handling of Reported Violations

The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Confidentiality

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

While we encourage individuals to provide their name when reporting violations or suspected violations in order to assist us in following up on the reported matter, we have made arrangements to allow for anonymous reports.

Reporting Violations

The Code addresses the IMRF’s open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern.

However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with someone in Human Resources or anyone in management whom you are comfortable in approaching.

Supervisors and managers are required to report suspected violations of the Code of Conduct to IMRF’s Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable with following the IMRF’s open door policy, individuals should contact IMRF’s Compliance Officer directly.

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

While we encourage individuals to provide their name when reporting violations or suspected violations in order to assist us in following up on the reported matter, we have made arrangements to allow for anonymous reports.

Reporting - How To

If you want to assure your anonymity, do not place a call or go to the web site from the offices of IMRF. These anonymous reports will be forward to IMRF’s Compliance Officer for investigation.