Governance Structure
1. Compliance Oversight
To ensure the effective management and oversight of its compliance efforts, Flipside AI
employs a robust governance structure:
Compliance Officer: A dedicated individual responsible for developing, implementing, and monitoring compliance policies and practices across the organization.
Ethics Committee: A diverse team comprising representatives from key organizational units, including operations, finance, human resources, and IT. The committee is tasked with:
- Providing balanced perspectives on ethical issues and compliance challenges.
- Reviewing and approving organizational ethics policies and practices.
- Addressing and resolving ethical concerns raised by employees or stakeholders.
- Monitoring adherence to the company’s core values and compliance requirements.
- Offering guidance on complex ethical dilemmas and promoting a culture of integrity throughout the organization.
2. Accountability and Reporting
Roles and responsibilities are clearly defined to maintain a culture of ethical behavior and
accountability:
Departmental Accountability: Department heads are tasked with ensuring compliance
within their teams, fostering a culture of integrity, and upholding organizational values.
Escalation Protocols: A structured chain of responsibility is in place for escalating
concerns, ensuring timely resolution and transparency in addressing ethical or
compliance issues.
This governance structure reflects our core values of integrity, accountability, and collaboration,
ensuring that ethical practices are embedded in every aspect of our operations.
Training and Communication
Ethics Training Program
Introduction to the Code of Ethics
- Provide an in-depth overview of the organization's core ethical principles.
- Emphasize the importance of maintaining integrity, honesty, and accountability in daily activities.
- Include clear explanations of policies on conflicts of interest, compliance, and legal responsibilities.
Ongoing Education and Refresher Training
- Schedule regular training sessions to reinforce ethical policies, ensuring they remain top-of-mind.
- Implement quarterly or bi-annual refresher courses that cover new developments in ethics, case studies, and updates to company policies.
Clear Communication Channels for Ethics Policies
1. Accessible and Consistent Communication
- Publish the Code of Ethics in the employee handbook and other internal communication channels.
- Send reminders about key ethical practices through internal communication channels to keep them fresh in employees' minds.
2. Feedback and Open Dialogue
- Establish clear channels for employees to ask questions, report concerns, or seek clarification on ethical issues.
- Regularly solicit feedback on the effectiveness of ethics training and communication, making adjustments based on employee input.
Risk Assessment
1. Identification of Ethical Risk Areas
Financial Integrity and Fraud Prevention
- Assess processes related to financial reporting to identify potential for errors, manipulation, or fraudulent activities.
- Review internal controls and safeguard mechanisms to ensure accuracy and transparency in financial documentation.
Data Privacy and Protection
- Evaluate practices surrounding the collection, storage, and handling of sensitive customer and employee data.
- Examine compliance with data protection laws (e.g., GDPR, CCPA) and internal protocols for safeguarding privacy.
Regulatory Compliance and Industry-Specific Risks
- Conduct a thorough assessment of industry-specific regulations to identify compliance gaps.
- Review any changes in local, state, or federal laws that could impact ethical practices, ensuring the company adapts to these updates.
Conflict of Interest and Whistleblower Protections
- Identify situations where conflicts of interest may arise, particularly in procurement, decision-making, and recruitment.
- Review systems for reporting unethical behavior to ensure a safe, anonymous process for whistleblowers.
Annual or Triggered Risk Assessments
- Establish an annual review cycle to assess evolving ethical risks and adapt the risk management strategy accordingly.
- In addition to regular reviews, conduct assessments following major organizational changes.
Cross-Departmental Collaboration
- Involve key stakeholders from various departments (e.g., finance, IT, HR) in the risk review process to gather diverse insights on potential risks.
Engagement of External Auditors and Experts
- Bring in independent auditors or external ethics experts to conduct thorough evaluations, ensuring objectivity and identifying overlooked risks.
- Use external audits as a benchmark for comparing the organization's practices to industry standards and best practices.
Ongoing Risk Monitoring and Mitigation
Continuous Monitoring of Key Risk Areas
- Implement systems for ongoing monitoring of identified risk areas, such as fraud detection tools, data protection systems, and regulatory compliance dashboards.
- Provide regular updates to senior leadership on the status of ethical risks and emerging challenges.
Immediate Response Protocol
- Create an immediate action plan for mitigating risks as they are detected, including clear escalation procedures, communication strategies, and corrective actions.
Feedback Loop and Adaptation
Post-Assessment Action Plans
- After each risk review, develop and communicate specific action plans for addressing discovered vulnerabilities, assigning responsibility to relevant stakeholders.
- Track progress against these action plans to ensure effective risk management and continuous improvement.
Employee Involvement in Risk Identification
- Engage employees at all levels in identifying potential ethical risks by promoting a culture of open communication and proactive reporting.
- Provide training on how employees can identify, report, and manage risks in their day-to-day responsibilities.
Reporting and Whistleblower Policies
Anonymous and Confidential Reporting System
Secure Reporting Channels
- Implement an anonymous reporting system to provide employees with a safe and accessible way to report ethics concerns.
Guarantee Anonymity and Retaliation Protections
- Establish strict confidentiality protocols to ensure reporters’ identities remain anonymous unless they choose otherwise.
- Communicate a zero-tolerance policy for retaliation, reinforcing that employees will not face adverse consequences for reporting ethical concerns in good faith.
Clear and Transparent Reporting Protocols
Defined Steps for Raising Concerns
- Clearly outline the steps employees should follow when reporting an issue, including whom to contact (e.g., managers, HR, or the Compliance Officer) and the available reporting platforms.
- Provide simple, easy-to-follow instructions to eliminate confusion and encourage timely reporting of concerns.
Timelines and Follow-Up
- Specify timeframes for acknowledging receipt of a report, initiating an investigation, and providing updates to the reporter, where possible.
- Maintain communication throughout the process to reassure employees that their concerns are being taken seriously and addressed appropriately.
Employee Awareness and Training
Regular Education
- Train employees on how to identify unethical behavior and use the reporting system effectively.
- Conduct periodic refreshers to ensure awareness of reporting protocols and the organization's commitment to ethical practices.
Promotion of Reporting Channels
- Publicize the availability of the reporting system through the employee handbook and internal communication channels.
- Reinforce a culture where reporting ethical concerns is viewed as a positive and essential contribution to the organization’s integrity.
Enforcement and Disciplinary Actions
Consistent Enforcement
- Apply disciplinary actions uniformly to all employees
Robust Investigation and Resolution Process
Fair and Thorough Investigations
- Ensure all reports are investigated promptly and impartially by qualified personnel. Involve legal or compliance experts when necessary.
- Document all steps of the investigation to maintain transparency and create an audit trail for accountability.
Resolution and Feedback
- Communicate the outcomes of investigations to the extent permissible, ensuring the employee understands how their concerns were addressed.
- Implement corrective actions or systemic changes based on findings to prevent recurrence of similar issues.
Continuous Improvement and Accountability
Monitoring and Review
- Regularly assess the effectiveness of the reporting system and whistleblower protections through employee surveys, feedback, and audit findings.
Leadership Accountability
- Hold leaders and managers accountable for fostering a supportive environment where employees feel safe to report concerns without fear of retaliation.
A Message from Our CEO
"As CEO, I am proud to affirm Flipside AI’s unwavering commitment to integrity and ethical
business practices. Our ethics program is not just a policy—it is a cornerstone of our culture and
a guiding principle in everything we do. By upholding the highest standards of fairness,
transparency, and accountability, we not only build trust with our employees and partners but
also ensure we meet and exceed the expectations of our customers. Their needs and requirements inspire us to always operate with excellence and ensure that ethical decision-
making remains at the forefront of our business. Together, we will continue to foster an environment where doing the right thing is always our first priority."
Anthony de Luna
President and CEO