Sieda Community Action does not discriminate on the basis of race, creed, color, national origin, religion, sex, age, disability, pregnancy, military membership or veteran status, sexual orientation or gender identity status in determining eligibility or delivering services to clients or potential clients. Not all prohibition bases apply to all programs.Program eligibility criteria will be provided when requested.
POLICY ON SERVING PERSONS WITH LIMITED ENGLISH PROFICIENCY (LEP)
Sieda Community Action is committed to providing equal opportunity in all programs and services to ensure full compliance with all civil rights laws, including Title VI of the 1964 Civil Rights Act, which prohibits discrimination on the basis of national origin and includes persons with Limited English Proficiency (LEP).
It is the policy of the agency to provide at no cost language access services to persons with LEP who are eligible to be served as soon as practicable.
The Agency and all staff working with persons of LEP will comply with the intent of this policy to afford meaningful access to services and programs, and will make every effort needed to provide services to such persons.
WHISTLE BLOWER POLICY:
Sieda Community Action believes that the organization should have policies in place to act on:
- The receipt, retention and treatment of complaints received by the organization regarding accounting, internal controls, or auditing matters.
- The submission of concerns regarding questionable accounting or audit matters by employees, directors and other stakeholders of the organization, on a confidential and anonymous basis.
Employees, board members and other volunteers are to observe high standards of business and personal ethics in conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
Each employee has an obligation to report (a) questionable or improper accounting or auditing matters, and (b) violations and suspected violations of the Sieda Personal Policies and Procedures Manual (hereinafter collectively referred to as Concerns).
Authority of Audit Committee
All reported concerns would be forwarded to the Executive Committee of the Sieda Board of Directors. The Executive Committee shall be responsible for investigating, and making appropriate recommendations to the Board of Directors, with respect to all reported Concerns.
This Whistleblower Policy is intended to encourage and enable employees and volunteers to raise Concerns within the organization for investigation and appropriate action. With this goal in mind, no volunteer, or employee who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, a volunteer or employee who retaliates against someone who has report a Concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.
Employees should first discuss their Concern with their immediate supervisor. If, after speaking with her or his supervisor, the individual continues to have reasonable grounds to believe the Concern is valid, the individual should report the Concern to the Division Director. In addition, if the individual is uncomfortable speaking with her or his supervisor, or the supervisor is the subject of the Concern, the individual should report his or her concern directly to the Executive Director.
If the Concern was reported verbally to the immediate supervisor, Division Director or Executive Director, the reporting individual, with assistance from the Fiscal Officer, shall reduce the Concern to writing. The Executive Director is required to promptly report the Concern to the Chair of the Executive Committee, which has specific and exclusive responsibility to investigate all Concerns. If the Executive Director, for any reason, does not promptly forward the Concern to the Audit Committee, the reporting individual should directly report the Concern to the Chair of the Executive Committee. Contact information for the Chair of the Executive Committee may be obtained through the Executive Director. Concerns may be also submitted anonymously. Such anonymous Concerns should be in writing and sent directly to the Chair of the Audit Committee. Concerns may also be submitted to:
- Department of Community Action Agencies
- Office of Citizens' Aide
- Auditor of State
- Iowa Attorney General
Volunteers should submit Concerns in writing directly to the Chair of the Executive Committee. Contact information for the Chair for the Executive Committee may be obtained for the Executive Director or the Fiscal Officer.
Handling of Reported Violations
The Executive Committee shall address all reported Concerns. The Chair of the Executive Committee shall immediately notify the Executive Committee, the Board Chairman, the Executive Director and the Fiscal Officer of any such report. The Chair of the Executive committee will notify the sender and acknowledge receipt of the Concern within 5 business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted Concerns.
All reports will be promptly investigated by the Executive Committee, and appropriate corrective action will be recommended to the Board of Directors, if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the Concern. The Executive Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the Codes. No adverse action will be taken against a staff person for reporting any ethical concern.
The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.
Reports of Concerns, and investigation pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.
COMMUNITY CONCERN/COMPLAINT PROCEDURE
It is the intent of Sieda to be proactive in soliciting constructive suggestions for quality improvement of the agency and the programs that it administers. In order to accomplish this goal, the agency will utilize the following procedure to advise the community of the availability of the agency’s procedure to receive and respond to community concerns, complaints and constructive suggestions.
STEP 1: Unit Director
Any complaint dealing with the provision of a specific service or program should be presented in writing to the Unit Director. The complaint should be in writing and contain sufficient detail to identify the nature of the concern or complaint. The complaint should be submitted within ten (10) working days of knowledge of the incident or circumstances involved. Anonymous complaints will not be investigated.
The Unit Director will investigate the circumstances of the incident and will consult with the Executive Director regarding the investigation of the complaint. The Unit Director will issue a written response within ten (10) working days of receipt of the complaint and, if related to the Head Start program, advise the Head Start Policy Council of the nature and disposition of the concern/complaint.
STEP 2: Executive Director
If the individual(s) initiating the above concern/complaint remains dissatisfied with the response of the Unit Director, a written request for review may be made to the Executive Director. Any complaint dealing with a policy or procedure of the agency as a whole should be initiated at the level of the Executive Director.
The Executive Director will investigate the complaint, meeting with the interested individuals as appropriate. If the complaint/concern is related to the Head Start program, the Executive Director will confer with the Head Start Policy Council and advise the Policy Council regarding the disposition of the investigation. The Executive Director, whose decision is final and binding on all non-policy items, will issue a written decision within ten (10) working days of receiving the request.
STEP 3: Board of Directors/Policy Council
If the individual(s) initiating the concern/complaint remains dissatisfied with the response of the Executive Director and the circumstances of the concern/complaint relate to a policy of the agency, a written request for review may be made to the Chairman of the Board of Directors.
The Executive Committee of the Board of Directors, in consultation with the Executive Committee of the Head Start Policy Council if the complaint/concern is related to the Head Start program, will investigate the complaint and issue a response following the next regularly scheduled board meeting that occurs at least ten (10) working days from the receipt of the complaint by the chairman of the board.
If the complaint involves an issue that relates to the Head Start program and the Head Start Policy Council and Sieda Board of Directors cannot reach agreement as to the appropriate response to the complaint, the issue will be referred to the Mediation Procedure of the agency.
STEP 4: Iowa Department of Human Rights/Division of Community Action Agencies
If the client remains dissatisfied, the client may request a state hearing. Sieda will request the hearing on behalf of the client, and forward all the information about the request to the Iowa Department of Human Rights/Division of Community Action Agencies (DCAA). Once requested, the client will be contacted by the DCAA and a state hearing will be scheduled. The state hearing will be conducted before the Administrator of the DCAA and appropriate staff, unless the complaint is delegated to an administrative law judge. Within 30 calendar days, following the hearing, the client will receive a written notification of any final or proposed decision.
STEP 5: Funding Agency
Further appeal may be directed to the funding agency, if different from the Division of Community Action Agencies or through civil proceedings as appropriate.