USA Gymnastics Whistleblower Policy
General
USA Gymnastics requires that directors, officers and employees observe high standards of
business and ethical conduct in performing their duties and responsibilities. As
representatives and employees of USA Gymnastics, we must practice honesty and integrity in
fulfilling our responsibilities and comply with the Bylaws of USA Gymnastics, the USA
Gymnastics Code of Ethical Conduct (“Code”), applicable policies and procedures of USA
Gymnastics, and all applicable laws and regulations.
Reporting Responsibility
It is the responsibility of all directors, officers, and employees to report a violation or
suspected violation of the Bylaws, the Code, applicable policies or procedures of USA
Gymnastics, or accounting practices, laws or regulations that govern the operations of USA
Gymnastics (collectively “Violation”) in accordance with this Whistleblower Policy. This Policy
is intended to address Violations, which are viewed as serious matters, and should not be
utilized as a substitute for complaints that should be addressed pursuant to the USA
Gymnastics’ Employee Policies and Procedures Handbook (“Handbook”). This Policy is not
intended to replace or supersede the Handbook.
No Retaliation
No director, officer, or employee (“Reporting Person”), who in good faith reports a Violation,
shall suffer harassment, retaliation or any adverse employment consequence, including, but
not limited to, termination, suspension, compensation decreases, poor work assignments
and/or threats of any nature. Anyone who retaliates against a Reporting Person who has
reported a Violation in good faith is subject to discipline as detailed in the Bylaws, the Code,
applicable policies or procedures of USA Gymnastics or the Handbook. This Whistleblower
Policy is intended to encourage and enable employees and others to raise serious concerns
within USA Gymnastics prior to seeking resolution outside of the organization. The right of a
Reporting Person for protection against retaliation does not include immunity for any personal
wrongdoing.
Reporting Procedure
USA Gymnastics has an open door policy and suggests that employees and other individuals
share their questions, concerns, suggestions or complaints with the President or another
member of the Senior Management Team who you are comfortable approaching. Those
individuals are required to report a suspected Violation to the USA Gymnastics Compliance
August, 2014 Officer. For suspected fraud, or when you are not satisfied or comfortable with following the
USA Gymnastics open door policy, individuals should contact the President or the USA
Gymnastics Compliance Officer directly.
Compliance Officer
The USA Gymnastics Compliance Officer is responsible for initially reviewing reports of
suspected Violations and determining the steps to be taken to investigate and seek resolution
of all reported complaints and allegations concerning any suspected Violation. In doing so, the
Compliance Officer may, at his/her discretion, advise the President and/or the Finance,
Compensation and Audit Committee (“Committee”). The Compliance Officer has direct access
to the President and the Committee and is required to report to the Committee at least
annually on compliance activities. The USA Gymnastics Compliance Officer is David Benck
([email protected]).
Accounting and Auditing Matters
The Committee shall address all reported concerns or complaints regarding corporate
accounting practices, internal controls or auditing. The Compliance Officer shall immediately
notify this Committee of any such complaint and be available to this Committee in the process
of resolving the matter.
Acting in Good Faith
A Reporting Person who files a complaint concerning a Violation or a suspected Violation must
be acting in good faith and have reasonable grounds for believing the information disclosed
indicates a Violation. 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
A Violation or suspected Violation may be submitted on a confidential basis by a Reporting
Person. Reports of a Violation or suspected Violation will be kept confidential to the extent
possible, consistent with the need to conduct an adequate investigation.
Handling of a Reported Violation
The Compliance Officer will acknowledge the receipt of the reported Violation or suspected
Violation to the Reporting Person. All reports will be timely investigated and appropriate
corrective action will be taken if warranted by the investigation.
Publication
USA Gymnastics Whistleblower Policy will be added to Section 5 (Rules of Conduct and
Performance) of the Handbook and will be posted on the organization’s website.
August, 2014