Employee Hotline Policy

Employee Hotline Policy

The Company is committed to the highest possible standards of ethical, moral, and legal business conduct. In conjunction with this commitment and our commitment to open communication, this policy aims to provide another avenue for employees to raise concerns and reassurance that they will be protected from retaliation in any form for raising awareness of issues in good faith. However, if an employee feels that their anonymity is not required, then they should follow our existing grievance procedure.

Retaliation
Retaliation in any form against individuals submitting hotline reports will not be tolerated.

Confidentiality
The policy is intended to cover serious concerns that could have a large impact on the facility, such as actions that

  • may lead to incorrect financial reporting;
  • are unlawful;
  • are not in line with company policy, including standards of conduct and professionalism outlined in the employee handbook; or
  • otherwise amount to serious improper conduct.

Regular business matters that do not require anonymity should be directed to the employee’s supervisor, the administrator, or to the resource center.

Every effort will be made to protect the reporter’s identity by our hotline vendor. Please note that the information provided in a hotline report may be the basis of an internal and/or external investigation by the facility into the issue being reported. It is possible that as a result of the information provided in a report, the reporter’s identity may become known to us during the course of our investigation.

Anonymous Allegations
The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to

  • the seriousness of the issue raised;
  • the credibility of the concern; and
  • the likelihood of confirming the allegation from attributable sources.

Malicious Allegations
Malicious allegations may result in disciplinary action.

Reporting
The reporting procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting or unethical/illegal conduct should be reported in one of the following ways:

  • Website: www.lighthouse-services.com/aspenskilledhealth
  • English-speaking USA and Canada: (800) 650-0004 (not available from Mexico)
  • Spanish-speaking North America: (800) 216-1288 (from Mexico, user must dial 001-800-681-5340)
  • E-mail: reports@lighthouse-services.com (must include company name with report)
  • Fax alternative for written documents: 215-689-3885 (must include company name with report)

Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting, and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided.

Reports are submitted by Lighthouse to the facility or its designee and may or may not be investigated at the facility’s sole discretion.

Employment-related concerns should continue to be reported through your normal channels, such as your supervisor, the facility administrator, a human resources representative, any member of management, the vice president of compliance, or the resource center at 949-347-7100.

Timing
The earlier a concern is expressed, the easier it is for us to take action.

Evidence
Although you are not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern.

Responding to a Report
The action taken will depend on the nature of the concern. The administrator and the resource center receive a copy of each report and follow-up reports on actions taken by the facility.

Initial Inquiries
Initial inquiries will be made to determine whether an investigation is appropriate and the form that it should take. Some concerns may be resolved by agreed-upon action without the need for an investigation.

Feedback to Reporter
Whether reported directly to facility personnel or through the hotline, the individual submitting a report will be given the opportunity to receive follow-up on their concern:

  • Acknowledging that the concern was received
  • Indicating how the matter will be dealt with
  • Giving an estimate of the time that it will take for a final response
  • Telling them whether initial inquiries have been made
  • Telling them whether further investigations will follow, and if not, why not

Further Information
The amount of contact between the individual submitting a report and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the employee remains accessible for follow-up. Further information may be sought from the reporter.

Outcome of an Investigation
At the discretion of the facility and subject to legal and other constraints, the reporter may be entitled to receive information about the outcome of an investigation.

We reserve the right to modify or amend this policy at any time as may be deemed necessary.