Whistle Blower Privacy

WHISTLEBLOWER PROTECTION POLICY

 

          A.  Application.  This Whistleblower Protection Policy applies to all of the Organization’s staff, whether full-time, part-time, or temporary employees, to all volunteers, to all who provide contract services, and to all officers and directors, each of whom shall be entitled to protection. 

 

          B.  Reporting Credible Information.  A protected person shall be encouraged to report information relating to illegal practices or violations of policies of the Organization that such person in good faith has reasonable cause to believe is credible.  Information shall be reported to the CEO (the “Compliance Officer”), unless the report relates to the Compliance Officer, in which case the report shall be made to the Board of Directors, or the Oversight Committee.

 

          Anyone reporting a Violation must act in good faith, and have reasonable grounds for believing that the information shared in the report indicates that a Violation has occurred. 

 

          C.  Investigating Information.  The Compliance Officer shall promptly investigate each such report and prepare a written report to the Board of Directors.  In connection with such investigation, all persons entitled to protection shall provide the Compliance Officer with credible information.  All actions of the Compliance Officer in receiving and investigating the report and additional information shall endeavor to protect the confidentiality of all persons entitled to protection.

 

          D.  Confidentiality

 

          The Organization encourages anyone reporting a Violation to identify himself or herself when making a report in order to facilitate the investigation of the Violation.  However, reports may be submitted anonymously by writing to the Oversight Committee. Reports of Violations or suspected Violations will be kept confidential to the extent possible, with the understanding that confidentiality may not be maintained where identification is required by law or in order to enable the Organization or law enforcement to conduct an adequate investigation.   

 

          E.  Protection from Retaliation.  No person entitled to protection shall be subjected to retaliation, intimidation, harassment, or other adverse action for reporting information in accordance with this Policy. Any person entitled to protection who believes that he or she is the subject of any form of retaliation for such participation should immediately report the same as a violation of and in accordance with this Policy.

 

          Any individual within the Organization who retaliates against another individual who has reported a Violation in good faith or who, in good faith, has cooperated in the investigation of a Violation is subject to discipline, including termination of employment or volunteer status.

 

          F.  Dissemination and Implementation of Policy.  This Policy shall be disseminated in writing via e-mail to all staff and board members in addition the policy will be displayed on the organization’s website.  The Organization shall adopt procedures for implementation of this Policy, which may include:

(1)   documenting reported Violations;

(2)   working with the Oversight Committee to decide whether the reported Violation requires review by the Compliance Officer or should be directed to another person or department;

(3)  keeping the board of directors informed of the progress of the investigation;

(4)   interviewing employees;

(5)  requesting and reviewing relevant documents, and/or requesting that an auditor or counsel investigate the complaint; and

(6)  preparing a written record of the reported violation and its disposition, to be retained for a period of 7 years. 

 

The Compliance Officer or the Oversight Committee  shall communicate with the complainant about the status of the complaint, to the extent that the complainant’s identity is disclosed, at the conclusion of the investigation  to the extent consistent with any privacy or confidentiality limitations.