CMAP’s policy is designed to be in compliance with the Whistleblower Act (740 ILCS 174), and this policy shall be interpreted subject to the standards in the Whistleblower Act. The Whistleblower Act protects every citizen, including state and local government employees, when they blow the whistle on government corruption. It is the practice of CMAP not to allow retaliation for reports of wrongdoing, fraud, corruption, or waste made in good faith, and it is the duty of every CMAP employee to report suspected improprieties. It is, at the same time, unacceptable to file a report knowing it is false.
All members of the CMAP Board and employees, grantees, contractors, and vendors of CMAP are protected under this policy when reporting suspected improprieties.
Types of complaints
The following suspected improprieties should be reported:
- Violations of laws and regulations applicable to CMAP;
- Contract and procurement fraud or collusion involving contracts with CMAP contractors, subcontractors, suppliers, or vendors
- Misuse, embezzlement, or theft of CMAP property or funds;
- Bribery and acceptance of gratuities in connection with authorized CMAP operations or transactions with suppliers, contractors, subcontractors, and vendors;
- Employee misconduct, such as misuse of official position and acceptance of unauthorized gifts;
- Conflicts of interest, such as an employee doing business with CMAP under a different name; and
- Other unethical or illegal activities involving CMAP property, employees, agents, contractors, subcontractors, vendors or suppliers, such as identity theft, check fraud, or violation of computer crime statutes.
Duty to report
It is the duty of every CMAP Board member and employee to report suspected violations of the policy of which they are aware, and failure to act will lead to disciplinary actions. It is impermissible to file a report knowing it is false. Any employee who violates this prohibition will be subject to discipline in accordance with CMAP policy, up to and including separation from the agency.
Suspected policy violations or illegal acts may be reported in the following manner:
- CMAP employees may speak with their direct supervisor or the CMAP ethics officer (director of human resources). Employees can also speak to the deputy executive director if resolution with their direct supervisor or the ethics officer is not reached.
- Third parties may contact the CMAP ethics officer or deputy executive director by calling 312-454-0400.
Confidentiality of the complaints received by the CMAP ethics officer will be maintained to the fullest extent possible, consistent with the need to conduct an appropriate review. When possible, the CMAP ethics officer will notify the complainant and acknowledge receipt of the reported violation within seven business days of receipt of the complaint. The CMAP ethics officer will maintain a log of all complaints that are received, tracking their receipt, investigation, and resolution. This information will be reported to the CMAP Board Executive Committee semi-annually.
Accounting and auditing matters
The CMAP ethics officer shall refer action relating to concerns and complaints regarding CMAP’s accounting practices, internal controls, and auditing to the executive director, deputy executive director and Board Executive Committee. The CMAP ethics officer shall work with the Executive Committee until the matter is resolved.
Prohibition against retaliation
It is essential that CMAP employees and others be able to report suspected policy violations or illegal activity that they observe at CMAP without fear that they will lose their job, impede their ability to advance at CMAP, or otherwise be subject to retaliation by colleagues, supervisors, and others. For purposes of this policy, retaliation includes any of the following actions:
- Reducing or restricting an employee’s duties or responsibilities;
- Failing to promote or give a raise to an employee who, were it not for the report of noncompliant activity, would have received a promotion or raise;
- Terminating an employee; or
- Taking any similar action that is intended to retaliate against or “pay back” an employee for a report of non-compliance.
Those companies that have entered into a contractual relationship with CMAP are also covered under this policy. CMAP is prohibited from terminating or modifying the existing contract(s) or grant(s) of any third party in retaliation for reporting suspected violations, unless the violation relates to such contract(s) or grant(s), and CMAP shall take all reasonable steps to protect the identity of employee of any vendor who files a complaint hereunder.