Conflict of Interest Policy

Purpose of Policy:

To help persons holding positions of responsibility and trust in the WSCPA, including any of its officers, board members, committee members, key employees and staff, avoid any conduct which might give rise to a conflict of interest or the appearance of a conflict of interest. The WSCPA officers, board members, committee members, key employees and staff have a duty to avoid any conflict of interest, or appearance of such conflict.

Definition:

A conflict of interest exists when any person holding a WSCPA position of responsibility or any member of his or her immediate family: (1) will profit, directly or indirectly, from the activities of the WSCPA, (2) has any professional or business relationship with an organization or individual that will profit from the activities of the WSCPA, (3) is being paid by another organization that has a business relationship with the WSCPA, or (4) is a current, unpaid member of the board of directors or the staff of another organization that will profit from the activities of the WSCPA.

Statement of Policy:

Annually, any known or potential conflict of interest in connection with the WSCPA activities, on the part of any person holding a WSCPA position of responsibility shall be disclosed to the Board Chair or the President & CEO. Once such a disclosure has been made, the person making the disclosure shall abstain from presenting motions, voting, executing agreements or taking any other action related to the issue in question on behalf of the WSCPA, and he or she shall not use any personal influence in connection with such issue. However, any person who abstains from voting because of such actual or possible conflict of interest may briefly state his or her position on the matter and answer pertinent questions posed by other board or committee members when the person’s knowledge of the matter will assist the board or committee. The minutes of any meetings shall reflect that a disclosure was made and that the person having the actual or potential conflict of interest abstained from voting.

Board Approved: May 18, 2018

Antitrust Policy

Purpose of Policy:

To ensure the WSCPA's compliance with all applicable federal, state and local laws and regulations, including the antitrust laws. This statement of policy is adopted to help all persons holding positions of responsibility and trust in the WSCPA, including any of its officers, board members, committee members and staff, avoid any conduct which might violate those laws.

Definition:

Antitrust laws prohibit agreements or practices that restrict free trade and competition among business entities. It is a violation of antitrust laws for businesses to fix prices or, in general, to agree not to compete with each other. Antitrust laws also ban behavior designed to dominate a market and anti-competitive practices that tend to lead to such a dominant position. Such prohibited practices include predatory pricing, tying, price gouging, refusal to deal and others.

Statement of Policy:

During all membership, board, committee and other meetings of the WSCPA, and all meetings attended by representatives of the WSCPA, or in relation to such meetings, discussions of prices or price levels for professional accounting services, or any services offered by the WSCPA, with competitive firms or businesses are strictly prohibited. In addition, no discussion is permitted during or relating to such meetings of any elements of a firm, business or organization’s operations, including the WSCPA, which might influence prices or price levels for professional accounting services such as:

  • Cost of operations, supplies, labor or services
  • Allowance for discounts
  • Terms of sale, including credit arrangements
  • Profit margins and mark ups

Discussions relating to division of territories or customers, or limitations on the nature of business carried on or products sold are also prohibited in these meetings.

As leaders in the profession, the WSCPA representatives must also avoid violations of the antitrust laws when participating in meetings or conversations which are not sponsored or sanctioned by the WSCPA. During any meeting attended by the WSCPA representatives, where discussion borders on an area of antitrust sensitivity, the WSCPA representative shall request that the discussion be stopped and ask that the request be included in the meeting minutes, if any. If the discussion continues, the WSCPA representative shall excuse himself or herself from the meeting and request that the minutes show that he/she left the meeting at that point and why he or she left. Any such instance should be reported immediately to the President & CEO of the WSCPA.

Board Approved: May 18, 2018

Whistleblower Policy

Purpose of Policy:

To encourage and enable employees and others to raise serious concerns about fraudulent, dishonest, and other illegal conduct. The WSCPA requires its employees, volunteers, and vendors to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As representatives of the WSCPA, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Statement of Policy:

It is the WSCPA’s policy that all employees, volunteers, and vendors representing the WSCPA are responsible for complying with the high standards of conduct set by the WSCPA. Each employee, volunteer, and vendor is required to report violations or suspected violations of fraud, dishonest, or other illegal conduct. Employees, volunteers, vendors, the WSCPA members, or others shall make such reports in accordance with this Whistleblower Policy.

No person who in good faith reports a violation of the WSCPA’s high standards of conduct shall be subjected to harassment, retaliation, or other adverse consequence. All efforts will be made to keep reports of violations or suspected violations confidential to the extent possible. However, such confidentiality may not be maintained if it is necessary to disclose the reports, or information contained in the reports, in order to conduct an investigation and, if necessary, proceed with disciplinary or legal action. Reports of violations or suspected violations may also be submitted anonymously.

Employees, volunteers, and vendors shall bring to the attention of the WSCPA any concerns including but not limited to complaints, questions, or suggestions regarding fraudulent, dishonest, or other illegal conduct.

The Employee should bring such concerns, complaints, questions or suggestions to his/her supervisor. If, however, the employee does not believe his/her supervisor is in the best position to address an area of concern, or the employee is not comfortable discussing the concern with his/her supervisor, the employee is encouraged to speak with the WSCPA’s Human Resources Department, anyone in management whom he/she is comfortable in approaching, or the Chair of the Board of Directors. Additionally, if the employee is not satisfied with the supervisor’s response, he/she is encouraged to speak with the Human Resources Department, anyone in management whom he/she is comfortable in approaching, or the Chair of the Board of Directors. The Human Resources Department and supervisors and managers are required to report suspected potential violations to the President & CEO, who will investigate all reported violations. The President & CEO shall inform the Chair of the Board of Directors of all reports where a violation is found to have occurred and the ultimate resolution of the matter.

Volunteers, vendors and members should bring such concerns, complaints, questions or suggestions to the WSCPA’s Human Resources Department or the President & CEO, who will investigate all reported violations. The President & CEO shall inform the Chair of the Board of Directors of all reports where a violation is found to have occurred and the ultimate resolution of the matter.

When an employee is uncomfortable reporting the fraudulent, dishonest, or other illegal conduct, for any reason, to his/her supervisor, is dissatisfied with the resolution of the concern, or if the President & CEO is the subject of the concern raised by the employee, the employee should contact the company, Fraud Hotline, which provides an independent, technology based, confidential and anonymous hotline service for reporting concerns regarding such conduct.

Volunteers, vendors and members who are uncomfortable reporting fraudulent, dishonest, or other illegal conduct, for any reason, to the WSCPA’s Human Resources Department or the President & CEO also should contact *Fraud Hotline. The recipients of the reports prepared by Fraud Hotline are the WSCPA’s Chair of the Board of Directors, the WSCPA President & CEO, and the Manager of Human Resources. Fraud Hotline’s contact information and reporting procedures shall be appropriately communicated. This service shall be available for use by employees, volunteers, vendors, and members.

All individual and Fraud Hotline’s reports of concerns made by employees, volunteers, or vendors shall be promptly acknowledged by the President & CEO and investigated by the President & CEO or a person delegated such responsibilities by the President & CEO. Appropriate corrective action shall be taken by the President & CEO if warranted by the investigation. If the reported concern involves conduct by the President & CEO, the Chair of the Board of Directors shall promptly acknowledge the report and investigate or arrange for an investigation of the reported conduct.

*To access the Fraud Hotline, please contact the Human Resources Director at 425-586-1116.

Board Approved: May 18, 2018

WSCPA Anti-Harassment Policy

It is the policy of WSCPA to maintain a work environment free from all forms of harassment on the basis of any status or characteristic protected by law.

WSCPA prohibits harassment by and toward employees, managers, and third parties such as members, instructors, vendors, or contractors. Unacceptable conduct includes offensive verbal comments, use of slurs or derogatory terms, stalking, intimidation, physical assault or battery relating to a person's race, religion, color, national origin, age, sex, genetic information, the presence of a any sensory, physical, or mental disability, marital status, honorably discharged veteran or military status, sexual orientation, gender identity, citizenship or immigration status, and status as a victim of domestic violence, sexual assault, or stalking, or on any other status or characteristic protected by federal, state, or local law.

Discriminatory Harassment. Harassment does not require intent to offend. Thus, inappropriate conduct or language meant as a joke, a prank, or even a compliment can lead to or contribute to harassment. Sexual or other harassing conduct, even if not unlawful, will not be tolerated. For example, a stray comment that degrades an employee’s gender may not be unlawful harassment, but it is an example of prohibited conduct under this policy.

Examples of prohibited discriminatory harassment include, but are not limited to:

  • Gender-biased statements, such as stereotypes about women or men;
  • Mocking or teasing a person having a disability or perceived disability;
  • Use of ethnic slurs or derogatory terms relating to an individual’s gender or sexual orientation;
  • Distribution of racially or sexually offensive e-mail or other electronic communications; and/or
  • Threatening, intimidating, or hostile acts directed at a sex or religious group or directed at an individual because of their sexual orientation, color or ethnicity.

Sexual Harassment. Sexual harassment is a specific type of discriminatory harassment. This includes comments or conduct of a sexual nature and behavior that tends to threaten or offend an employee. Any behavior toward any employee by a manager, supervisor, co-worker, or third parties such as vendors and customers which constitutes unwelcome sexual advances, requests for sexual favors, the display of sexual images, use of the Internet to display or distribute sexually explicit images or messages and verbal or physical conduct of a sexual nature violates this policy, including when:

  1. Submission to such conduct is made a condition of an individual’s employment;
  2. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; and/or
  3. Such conduct has the purpose or effect of interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment.

This policy prohibits unacceptable harassment or conduct in the workplace and at organizational sponsored business and social events or meetings, or events with co-workers entirely unrelated to the workplace, by an employee, manager, or third party. Additionally, harassment or conduct via social media, email and text messages are within the scope of prohibited conduct; for example, a harassing or discriminating post on an employee’s or third party’s private social media page or via other social media violates this policy. Any employee violating this policy may be subject to corrective action up to and including termination of employment. Any third party or member violating this policy may be subject to termination of the relationship or WSCPA membership.

Complaint Procedure. If you believe that you have been the object of harassment or conduct in violation of this policy, or if you witness harassment or inappropriate conduct, report the incident to the *Human Resources Director. If the individual from Human Resources is the cause of the problem, seems unwilling to resolve the issue, or appears unresponsive, please contact the *Fraud Hotline. Any supervisor or manager who witnesses an act of harassment or who receives a complaint of harassment and fails to take appropriate action, which includes reporting the act or complaint to Human Resources, may be subject to disciplinary action.

All complaints about an employee or non-employee will be thoroughly and promptly investigated. Every complaint will be kept confidential to the maximum extent possible. All employees have an obligation to cooperate in an investigation of harassment complaints. The results of any investigation will be communicated to the complaining employee(s). Prompt and appropriate corrective action will be taken if the company concludes that an employee or non-employee has engaged in harassing conduct, even if the conduct is not unlawful. Corrective action may include discipline up to and including termination of employment or the relationship with the third party or WSCPA membership.

Retaliation. Complaining employee(s), witnesses to an investigation, and employees associated with a complaining employee or witness, such as a spouse, will be afforded protection from retaliation. Examples of prohibited retaliation include: discharge, material changes to terms and conditions of employment, and ostracism or disparagement of an individual. Retaliation is prohibited even in the case where an underlying complaint has no merit. No employee may be subject to retaliation for bringing a complaint of harassment, for filing a Charge of Discrimination or lawsuit, or for participating as a witness in an investigation, Charge or lawsuit.

Employees who believe they have been subject to retaliation must immediately bring it to the attention of the Human Resources Director.

Third parties such as members, instructors, vendors, or contractors who believe they have been subject to retaliation should also immediately bring it to the attention of the Human Resources Director.

Fraud Hotline. Employees or third parties such as members, instructors, vendors, or contractors who are uncomfortable reporting harassment of any nature, or retaliation for any reason, to the Human Resources Director, is dissatisfied with the resolution of the concern, or if the President & CEO is the subject of the concern raised, are encouraged to contact the *Fraud Hotline. Complaints of retaliation will be investigated and addressed according to this policy.

*To access the Fraud Hotline, or contact the Human Resources Director, call 425-586-1116.

Adopted: May 17, 2019