The IACPM is a non-profit organization dedicated to advancing the practice of credit portfolio management.
IACPM Weekly SmartBrief
Essential News for Credit Portfolio Management Professionals
Banks aim to restructure one-way collateralized-swaps agreements
The International Association of Credit Portfolio Managers, Inc. (the "Association") is committed to lawful and ethical behavior in all of its activities and requires staff and volunteers to act in accordance with all applicable laws, regulations and policies and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. This Whistleblower Policy (1) encourages staff and volunteers to come forward with credible information on illegal practices or material violations of adopted policies of the Association; (2) specifies that the Association will protect the person from retaliation; and (3) identifies where such information can be reported.
1. Encouragement of reporting. The Association encourages complaints, reports or inquiries about illegal practices or material violations of the Association’s policies, including illegal or improper conduct by the Association itself, by its leadership, or by others on its behalf. Appropriate subjects to raise under this policy include financial improprieties, accounting or audit matters, ethical violations, or other similar illegal or improper practices or policies. Other subjects on which the Association has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment via the Association’s human resources channels, unless those channels are themselves implicated in the wrongdoing. This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.
2. Protection from retaliation. The Association prohibits retaliation by or on behalf of the Association against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This protection extends to those whose allegations are made in good faith but prove to be mistaken. The Association reserves the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports or inquiries or who otherwise abuse this policy.
3. Where to report. Complaints, reports or inquiries may be made under this policy on a confidential or anonymous basis. They should describe in detail the specific facts demonstrating the bases for the complaints, reports or inquiries. Each complaint, report or inquiry under this policy should be directed to the Association’s Executive Director or Chairman of the Board of Directors; if both of those persons are implicated in the complaint, report or inquiry, it should be directed to the Association’s Associate Director, or any other member of the Association’s Executive Committee (Vice-chair, Treasurer or Secretary).
4. Handling of complaints, reports and inquiries. The Association will investigate all complaints, reports and inquiries filed in accordance with this policy with due care and promptness. Staff or volunteers must recognize that the Association may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously.