1. Introduction
This Ethics and Reporting Policy ("Policy") governs the process by which VA WORKS, LLC ("VA WORKS™," "Consultant," "we," "us," or "our") receives, assesses, and investigates reports of alleged misconduct, irregularities, or breaches of policy. This Policy forms an integral part of the Master Service Agreement ("MSA"), the MSA Terms and Conditions (https://vaworks.com/MasterServiceAgreement), the applicable Scope of Work Terms and Conditions (https://vaworks.com/SOWSelection), and the Governing Policies referenced therein.
The purpose of this Policy is to safeguard the integrity, governance, and reputation of Consultant while encouraging employees, independent contractors, and stakeholders to report concerns in good faith without fear of retaliation. Nothing in this Policy limits the rights of any individual under applicable law or prevents direct communication with legal or regulatory authorities.
2. Scope
This Policy applies to all Consultant employees, independent contractors, suppliers, shareholders, and other stakeholders, including individuals whose working relationship with Consultant has ended or is yet to begin. It also extends to colleagues, relatives, or entities associated with reporting individuals.
3. Ethical Conduct Expectations
All employees, independent contractors, and stakeholders associated with Consultant are expected to uphold the highest standards of lawful, ethical, and professional conduct. This includes:
- Acting with honesty and integrity in all business dealings;
- Complying with applicable laws, regulations, and Consultant's Governing Policies;
- Respecting confidentiality and safeguarding information;
- Avoiding conflicts of interest and reporting them when they arise;
- Treating colleagues, clients, and third parties with fairness, dignity, and respect.
Failure to adhere to these expectations may result in corrective or disciplinary action, up to and including termination of employment, contract, or business relationship.
4. Reporting Channels
Reports should contain sufficient detail to allow proper evaluation, including the nature of the concern, names of individuals involved, dates, and supporting evidence where available. Reports may be submitted through any of the following channels:
- Email: admin@mxworks.com
- Mail: VA WORKS, LLC, 7726 Winegard Road, 2nd Floor, Orlando, FL 32809
- In-person: By arranging a physical meeting upon request
Consultant will acknowledge receipt of a report within seven (7) days of submission.
5. Investigation and Response
Reports will be evaluated for validity and relevance by designated personnel. If deemed valid, Consultant will conduct an impartial internal investigation. Feedback will be provided to the whistleblower within ninety (90) days, including the outcome of the investigation and any corrective measures taken or referrals to authorities, as appropriate.
The identity of whistleblowers will be kept confidential to the fullest extent permitted by law and will not be disclosed without consent, unless required by legal process.
6. Non-Retaliation
Consultant strictly prohibits retaliation of any kind against whistleblowers who report concerns in good faith. Any threats, harassment, intimidation, or adverse employment or contractual actions against whistleblowers will be treated as a serious violation and addressed immediately.
7. Oversight and Enforcement
Designated personnel, including members of Consultant's Legal and Human Resources functions, are responsible for administering this Policy with impartiality and confidentiality. Any breach of confidentiality, mishandling of a report, or conflict of interest by responsible personnel will be treated as a violation subject to disciplinary measures.
8. Review of Policy
This Policy will be reviewed annually, or sooner if significant regulatory or organizational changes occur, to ensure its continued compliance and effectiveness.