Updated November 2021
Purpose
It is the policy of WEDO to abide by all applicable federal, state, and local laws, rules, and regulations. Violations of legal provisions and ethical standards can taint the credibility of the entire organization and cause the organization and its employees to be subjected to adverse publicity and distrust by the public, our partners, and the government. WEDO takes seriously its obligation to prevent these kinds of violations.
Definition of Whistleblower
A whistleblower is a person, usually an employee, who exposes information or activity within a private, public, or government organization that is deemed illegal, illicit, unsafe, or a waste, fraud, or abuse of taxpayer funds.
Reporting and Investigations
If an employee believes that WEDO, through the acts of any of its employees or agents, is in violation of applicable law or its ethical obligations (including any allegations of possible fraudulent or dishonest use or misuse of resources or property), such conduct should be immediately reported to an appropriate manager. In most cases, the violation should be reported to an employee’s immediate supervisor in writing and signed by the employee. If this is not practical, or if that action is taken but does not correct the perceived violations, a written statement, signed and dated, should be made by the employee to the Director or the Director of Finance with the specific information that the employee knows, so that an investigation may be undertaken. If the alleged violation involves the conduct of the Executive Director, the violation should be reported in writing to the Chair of the Board.
Authority of Audit Committee
All reported Concerns will be forwarded to the Audit Committee in accordance with the procedures set forth herein. The Audit Committee shall be responsible for investigating, and making appropriate recommendations to the Board of Directors, with respect to all reported Concerns.
All complaints made under this policy will be investigated as promptly and confidentially as possible. All employees should act responsibly and truthfully in making allegations, responding to allegations, and providing information in an investigation. Any employee who is determined, after an investigation, to have violated applicable legal or ethical standards shall be subject to discipline, up to and including suspension and termination.
Reporting Concerns
Employees
Employees should first discuss their Concerns with their immediate supervisor. If, after speaking with their supervisor, the individual continues to have reasonable grounds to believe the Concern is valid, the individual should report the Concern to the Director. If the individual is uncomfortable speaking with their supervisor, or the supervisor is a subject of the Concern, the individual should express their Concern directly to the Director.
If the Concern was reported verbally to the Director, the reporting individual, with assistance from the Director, shall document the Concern in writing. The Director is required to promptly report the Concern to the Chair of the Audit Committee, which has specific and exclusive responsibility to investigate all Concerns. If the Director, for any reason, does not promptly forward the Concern to the Audit Committee, the reporting individual should directly report the Concern to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained through the Director. Concerns may also be submitted anonymously. Such anonymous Concerns should be in writing and sent directly to the Chair of the Audit Committee.
Directors, External Entities, and Other Volunteers
Directors, external entities, and other volunteers should submit Concerns in writing directly to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained from the Director.
Investigation Procedures
The Audit Committee shall address all reported Concerns. The Chair of the Audit Committee shall immediately notify the Audit Committee and the Director of any such report. The Chair of the Audit Committee will notify the sender and acknowledge receipt of the Concern within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted Concerns.
All reports will be promptly investigated by the Audit Committee, and appropriate corrective action will be recommended to the Board of Directors if warranted by the investigation. Action taken must include a conclusion and follow-up with the complainant for complete closure of the Concern.
The Audit Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a complete investigation of the allegations.
Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the Code. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.
WEDO will not retaliate against an employee for making a complaint under this policy in good faith or for participating in good faith in an investigation of a violation of this policy.
Confidentiality
Reports of Concerns, and investigation about it, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
