Code of Conduct/Ethics

Employee Training

Module
Module 1
1

Introduction
The success of our business is dependent on the trust and confidence we
earn from our employees, customers and shareholders.
We gain credibility by adhering to our commitments, displaying honesty
and integrity and reaching company goals solely through honorable
conduct.
It is easy to say what we must do, but the proof is in our actions.
Ultimately, we will be judged on what we do.

Introduction
When considering any action, it is wise to ask:
Will this build trust and credibility for CareerSource
Suncoast?
Will it help create a working environment in which
CareerSource Suncoast can succeed over the long
term?
Is the commitment I am making one I can follow
through with?
The only way we will maximize trust and credibility is by
answering Yes to those questions and by working every day to
build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity
and respect. CSS is committed to creating such an environment because
it brings out the full potential in each of us, which, in turn, contributes
directly to our business success. We cannot afford to let anyones talents
go to waste.
CareerSource Suncoast is an equal employment/affirmative action employer
and is committed to providing a workplace that is free of discrimination of
all types from abusive, offensive or harassing behavior. Any employee who
feels harassed or discriminated against should report the incident to his or
her manager or to human resources.

Open and Honest Communication

At CareerSource Suncoast everyone should feel comfortable to speak
his or her mind, particularly with respect to ethics concerns.
Managers have a responsibility to create an open and supportive
environment where employees feel comfortable raising such
questions. We all benefit tremendously when employees exercise their
power to prevent mistakes or wrongdoing by asking the right
questions at the right times.
CareerSource Suncoast will investigate all reported instances of
questionable or unethical behavior. In every instance where improper
behavior is found to have occurred, the company will take appropriate
action. We will not tolerate retaliation against employees who raise
genuine ethics concerns in good faith.

Whistleblower Policy
Background
Sections 112.3187 112.31895, Florida Statutes (F.S.) are
known as the Whistle-Blowers Act. The Sarbanes-Oxley
Act, signed into law on July 30, 2002, also deals with this
issue as it applies to non-profit corporations.
The intent of this legislation is to prevent agencies or
independent contractors from taking retaliatory action
against an employee who reports to an appropriate
agency violations of law on the part of a public employer,
as well as to prevent agencies or independent contractors
from taking retaliatory action against any person who
discloses information to an appropriate agency alleging
improper use of governmental office, gross waste of
funds, or any other abuse or gross neglect of duty on the
part of an agency, public officer, or employee.

Whistleblower Policy
In keeping with CSSs overarching policy of maintaining the
highest standards of conduct and ethics, CSS will investigate
any suspected fraudulent or dishonest use or misuse of CSSs
resources or property by staff, board members, consultants, or
volunteers. CSS is committed to maintaining the highest
standards of conduct and ethical behavior, and promotes a
working environment that values respect, fairness, and
integrity.
All staff, board members, and volunteers shall act with
honesty, integrity, and openness in all their dealings as
representatives for the organization. Failure to follow these
standards will result in disciplinary action including possible
termination of employment, dismissal from ones board or
volunteer duties, and possible civil or criminal prosecution if
warranted.

Whistleblower Protection
CSS will protect whistle-blowers as defined below:
CSS will use its best efforts to protect whistle-blowers
against retaliation. Whistle-blowing complaints will be
handled with sensitivity, discretion, and
confidentiality to the extent allowed by the
circumstances and the law. Generally this means that
whistle-blower complaints will only be shared with
those who have a need to know so that CSS can
conduct an effective investigation, and in appropriate
cases, with law enforcement personnel.
Should disciplinary or legal action be taken against a
person or persons as a result of a whistle-blower
complaint, such persons may also have right to know
the identity of the whistle-blower.

Whistleblower Protection
Baseless Allegations

Whistle-blowers must be cautious to avoid baseless allegations as

described below.
Baseless allegations are defined as allegations made with reckless
disregard for their truth or falsity. People making such allegations may
be subject to disciplinary action by CSS and/or legal claim by individuals
accused of such conduct.

Whistle Blower Protection

Fraudulent or Dishonest Conduct

Fraudulent or dishonest conduct is defined as a deliberate act or

failure to act with the intention of obtaining an unauthorized
benefit. Examples of such conduct include, but are not limited to:
Forgery or alteration of documents
Unauthorized alteration or manipulation of computer files
Fraudulent financial reporting
Management override of internal controls
Pursuit of a benefit or advantage in violation of CSSs Conflict of
Interest policy;
Misappropriation or misuse of CSS resources, such as funds,
supplies, or other assets;
Approving or receiving compensation for goods not received or
services not performed; and
Authorizing or receiving compensation for hours not worked.

Whistleblower Protection
Reporting

A persons concern about possible fraudulent or dishonest use or misuse of

resources or property should be reported to his or her supervisor or, if suspected
by a volunteer, to the staff member supporting the volunteers work. If for any reason
a person finds it difficult to report his or her concerns to a supervisor or staff member
supporting the volunteers work, the person may report the concern directly to the
Human Resource Director, Career Services and Business Services Directors, Chief
Financial/Administrative Officer, Chief Operating Officer, Business and Economic
Development Officer, or President. Alternately, to facilitate reporting of suspected
violations where the reporter wishes to remain anonymous, a written statement
may be submitted to one of the individuals by mailing to:

CareerSource Suncoast
1112 Manatee Ave East.,
Bradenton, FL. 34208
CSS staff can contact the Board Chair to leave a confidential voicemail message
regarding the concern on the Integrity Hotline at 941-358-4080, ext. 1119.

Whistleblower Protection
Supervisor Duties

Supervisors are required to report suspected fraudulent or

dishonest conduct to the Human Resource Director, Career
Center or Business Services Directors, Chief Financial and
Administrative Officer, Chief Operating Officer, Chief Economic
and Business Development Officer, the President/CEO, or the
Chair of CSS.
Reasonable care should be taken in dealing with suspected
misconduct to avoid:
Baseless allegations;
Premature notice to persons suspected of misconduct and/or
disclosure of suspected misconduct to others not involved
with the investigation; and
Violation of a persons rights under law.

Whistleblower Protection
Supervisor Duties

Due to the important yet sensitive nature of the suspected

violations, effective professional follow-up is critical.
Supervisors, while appropriately concerned about getting to
the bottom of such issues, should not in any
circumstances perform any investigative or other follow
up steps on their own. Accordingly, a supervisor who
becomes aware of suspected misconduct:
Should not contact the person suspected to further
investigate the matter or demand restitution.
Should not discuss the case with attorneys, the media, or
anyone other than the Human Resource Director, Career
Center and Business Services Directors, Chief Financial
and Administrative Officer, Chief Operating Officer, Chief
Business and Economic Development Officer, the
President/CEO, or the Chair of the CSS.
Should not report the case to an authorized law
enforcement officer without first discussing the case with
a Director, Officer, or Board Chair of CSS.