Whistleblower: An employee, consultant or volunteer who informs a supervisor, or the Executive Director about an activity relating to the company which that person believes to be fraudulent or dishonest, without having any concern about liability or retaliation against the reporter.

In keeping with the policy of maintaining the highest standards of conduct and ethics, our company will investigate any suspected fraudulent or dishonest use (or misuse) of company resources or property by staff, board members, consultants or volunteers - regardless of their seniority.

(^Company^) is committed to maintaining the highest standards of conduct and ethical behavior and promotes a working environment that values respect, fairness and integrity. All staff, board members and volunteers shall act with honesty, integrity and openness in all their dealings as representatives for the organization and comply with all applicable laws, regulations, policies and procedures. Failure to follow these standards will result in disciplinary action including possible termination of employment, dismissal from one’s board or volunteer duties and possible civil or criminal prosecution if warranted. Staff, board members, consultants and volunteers are encouraged to report the witnessing of any suspected fraudulent or dishonest conduct (i.e. to act as a “whistleblower”), pursuant to the procedures set forth below.

Reporting

A person’s concerns about possible fraudulent or dishonest use or misuse of resources or property should be reported to his or her supervisor or, if suspected by a volunteer, to the staff member supporting the volunteer’s work. If for any reason a person finds it difficult to report his or her concerns to a supervisor or staff member supporting the volunteer’s work (if, for example, their supervisor is the one suspected of misconduct), the person may report the concerns directly to Executive Director of the company. Alternatively, to facilitate reporting of suspected violations where the reporter wishes to remain anonymous, a written statement may be submitted to one of the individuals listed above. 

Baseless Allegations: Allegations made with reckless disregard for their truth or falsity.

People making baseless allegations may be subject to disciplinary action by the company, and/or legal claims by individuals accused of such conduct.

Fraudulent or Dishonest Conduct: A deliberate act or failure to act with the intention of obtaining an unauthorized benefit. 

Examples of fraudulent or dishonest conduct include, but are not limited to:

• Forgery or alternation of documents;
• Unauthorized alteration or manipulation of computer files;
• Fraudulent financial reporting;
• Pursuit of a benefit or advantage in violation of (^Company^)’s Conflict of Interest Policy;
• Misappropriation or misuse of (^Company^)’s resources, such as funds, supplies or other assets;
• Authorizing or receiving compensation for goods not received or services not performed; and
• Authorizing or receiving compensation for hours not worked

Rights and Responsibilities

Supervisors are required to report suspected fraudulent or dishonest conduct to the Executive Director of (^Company^) as soon as possible.

Reasonable care should be taken in dealing with suspected misconduct to avoid:

• Baseless allegations;
• Premature notice to persons suspected of misconduct and/or disclosure of suspected misconduct to others not involved with the investigation; and
• Violations of a person’s rights under law

Due to the important yet sensitive nature of the suspected violations, effective professional follow-up is critical. Supervisors, while appropriately concerned about “getting to the bottom” of such issues, should not in any circumstances perform any investigative or other follow-up steps on their own. Accordingly, a supervisor who becomes aware of suspected misconduct:

• Should not contact the person suspected to further investigate the matter or demand restitution.
• Should not discuss the case with attorneys, the media or anyone other than the Executive Director of the company.
• Should not report the case to an authorized law enforcement officer without adequate due-process and preferably proof of misconduct, unless a serious crime is suspected to have taken place.

Investigation

All relevant matters, including suspected but unproved matters, will be reviewed and analyzed, with documentation of the receipt, retention, investigation and treatment of the complaint. Appropriate corrective action will be taken, if necessary, and findings will be communicated back to the reporting person and his or her supervisor.

Investigations may warrant investigation by an independent person such as auditors and/or attorneys.

Whistleblower Protection

(^Company^) will protect whistleblowers as defined below:

• (^Company^) will use its best efforts to protect whistleblowers against retaliation. 
• Whistleblowing complaints will be handled with sensitivity, discretion and confidentiality to the extent allowed by the circumstances and the law. Generally this means that whistleblower complaints will only be shared with those who have a need to know so that the company can conduct an effective investigation, determine what actions to take based on the results of any such investigation, and in appropriate cases, with law enforcement personnel. 
• Should disciplinary or legal action be taken against a person or persons as a result of a whistleblower complaint, such persons may also have the right to know the identity of the whistleblower.
• Employees, consultants and volunteers of the company may not retaliate against a whistleblower for informing management about an activity which that person believes to be fraudulent or dishonest with the intent or effect of adversely affecting the terms or conditions of the whistleblower’s employment, including but not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary or fees. 
• Whistleblowers who believe that they have been retaliated against may file a written complaint with Executive Director of the company. Any complaint of retaliation will be promptly investigated and appropriate corrective measures taken if allegations of retaliation are substantiated. This protection from retaliation is not intended to prohibit supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.
• Whistleblowers must be cautious to avoid baseless allegations (as described earlier in the definitions section of the policy)