Whistleblower Protection Policy

Section 1. General:

The Corporation requires trustees, officers, employees, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Section 2. Reporting Responsibility:

It is the responsibility of all trustees, officers, employees, and volunteers to comply with the Corporation’s policies and to report violations or suspected violations of the law in accordance wih this Policy.

Section 3. No Retaliation:

No trustee, officer, employee, or volunteer, who in good faith reorts a violation of the law, shall suffer harassment, retaliation, or adverse employment consequence even if the report is mistaken, or against any employee or individual who assists in the investigation of a reported violation. An employee, officer or trustee who retaliates against someone who has reported a violation of the law in good faith is subject to disciplinary action up to and including termination of employment or removal from the organization. This Whistleblower Protection Policy is intended to encourage and enable employees and others to raise concerns about illegal activity within the organization.

Section 4. Reporting Alleged Violations:

Officers, trustees, and employees are expected to report suspected violations of the Corporation’s policies or illegal activities to the Executive Director or to the Chairman of the Board of Trustees. If either is alleged to be in violation of the law, then the report should be submitted to the Compliance Officer. A submitted report will be investigated by the Audit Committee with assistance from the Compliance Officer and from the Chairman and the Executive Director, if appropriate. The Executive Director is authorized to retain legal counsel on behalf of the Corporation in connection with alleged violations under this Article. The Compliance Officer is authorized to retain legal counsel on behalf of the Corporation to address a complaint under this Article if the complaint involves allegations of wrongdoing by the Chairman or the Executive Director. A report of findings of the internal investigation will be submitted by the Compliance Officer or his or her designee to the Board with recommendations for action.

Section 5. Compliance Officer:

The Corporation’s Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of Corporation policies or illegal activites and, at his or her discretion, shall advise the Executive Director and/or the Chairman of the Board of Trustees. The Compliance Officer, or his or her designee, shall have direct access to the Audit Committee of the Board of Trustees and shall report to the Audit Committee at least annually on compliance activity. Unless otherwise specified, the Secretary of the Board of Trustees serves as Corporation’s Compliance Officer and is appointed annually by the Board of Trustees. The Compliance Officer shall not serve simultaneously as the Chair of the Personnel Committee. The Compliance Officer may serve as Chair of the Audit Committee in the event that allegations under this article are made against the named Audit Committee Chair.

Section 6. Accounting and Auditing Matters:

The Audit Committee of the Board of Trustees shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The Compliance Officer shall immediately notify the Audit Committee of any such complaint and work with the committee until the matter is resolved.

Section 6. Acting in Good Faith:

Anyone filing a complaint concerning suspected illegal activity or a violation of Corporation policies must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law or Corporation policies. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as malfeasance and addressed accordingly.

Section 7. Confidentiality:

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Section 8. Handling of Reported Violations:

The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violations within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. If action is not warranted, the Board will provide a statement explaining why corrections are not necessary.


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