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(a) Fraud, Waste, and Abuse Hotline (Hotline).

(1) All WSSC employees and nonemployee stakeholders are encouraged to make a good faith report of any improper activities, violations and/or other suspected incidents of wrongdoing using our third-party-serviced 24 hours/seven days per week WSSC fraud, waste, and abuse hotline via telephone, email, fax, other written correspondence, or Internet (website).

(2) The facts reported are to be stated with as much specific information as possible so that the allegations can be adequately investigated. The reporting individual should not speculate or draw conclusions and should be prepared for possible questioning by interview specialists and/or investigators.

(3) Under no circumstances shall anyone directly or indirectly interfere with a hotline investigation, or induce or coerce others not to cooperate with investigators. Any attempt to directly or indirectly interfere with a hotline investigation is also prohibited and is subject to appropriate disciplinary action up to and including discharge.

(b) False Reports. Any intentional filing of false reports and/or false allegations is considered improper activity and is grounds for disciplinary action in accordance with the WSSC personnel policy (if reported by a WSSC employee.)

(c) Good Faith Reports. If investigators conclude there is reasonable belief by the reporting individual of improper activity, violations and/or suspected wrongdoings, and the reporting individual made a good faith report, then the reporting individual shall not be liable for filing a false report if his or her allegations are not substantiated.

(d) Nonretaliation.

(1) WSSC will not tolerate acts of retaliation against employees for good faith reporting and/or disclosure of alleged improper activities, violations, or other suspected wrongdoings whether or not such activity results in a finding of fraud, waste, or abuse of WSSC assets. Retaliation includes discipline, termination, demotion, suspension, threats and/or harassment.

(2) Efforts will be taken to protect the reporting WSSC employee from any retaliation. If a WSSC employee believes retaliation occurred, the Fair Practice Office will be notified to investigate the allegation(s). If allegations are confirmed, the WSSC will take the appropriate action.

(e) Investigations.

(1) Investigations are not limited to the aforementioned parties identified in WSSC 15.210.050, Roles and responsibilities. The primary investigative party and supporting investigative party will vary depending on the circumstances underlying the investigation.

(2) Upon receipt of an incident report, a third-party hotline interview specialist will commence to gather relevant facts. After incident reports are reviewed for quality assurance, they will be automatically disseminated to the recipients designated by the WSSC.

(3) Based on the information disseminated, the action warranted may include investigative work by a combination of resources outlined above. However, information sharing will only be done on a legitimate need-to-know basis with relevant parties, including external law enforcement officials.

(4) To the extent possible within the limitations of law, policy, and the need to conduct a competent investigation, an effort will be made to maintain confidentiality; however, it is possible that the identity of the reporting individual and that of the alleged violator may become known for reasons outside of the control of the investigator(s) and/or the WSSC.

(5) The details about the reporting mechanisms used, review and investigation of allegations and handling of outcomes is available in the related WSSC Fraud, Waste, and Abuse Hotline Operations Manual and Investigation Guidelines.

(f) Reporting Internal Investigations.

(1) At least quarterly, all WSSC primary investigators performing fraud, waste, and abuse investigations in accordance with the aforementioned guidelines are to report investigation results to the Internal Auditor.

(2) Summary reports that analyze incidents and hotline activity, including the results of all ongoing investigations, will be provided to management, the General Manager, and/or WSSC Commissioners, as appropriate for oversight responsibilities. (IA 09-02 (Res. 2010-1845) § VI)

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