Washington County Community Foundation Policy on Whistleblowers
Trustees, officers, employees, consultants, vendors, volunteers, and other agents of, and recipients of funds from, the Washington County Community Foundation (WCCF) are expected to observe high ethical standards of business and personal ethics in the conduct of their duties and responsibilities. Trustees, officers, employees, consultants, vendors, volunteers, other agents of, and recipients of funds from, the WCCF must practice honesty and integrity in fulfilling individual responsibilities and must comply with all applicable laws and regulations.
The WCCF has adopted this Whistleblower Policy to
(1) encourage all Trustees, officers, employees, consultants, vendors, volunteers, and other agents to come forward in writing, with credible information on illegal practices or serious violations of adopted policies of the WCCF; (2) ensure all such individuals that the WCCF will protect the person from retaliation; and (3) identify where such information can be reported and the process of handling the complaint. This policy shall be reviewed at least every five (5) years by the Legal Committee to ensure continued compliance with all applicable laws and regulations.
- Encouragement of reporting- The WCCF encourages complaints, reports or inquiries about illegal practices or violations of the WCCF’s policies, including illegal or improper conduct by the WCCF itself, by its leadership, or by others on its behalf. Appropriate subjects to raise under this policy would include financial improprieties, ethical violations, or other similar illegal or improper practices or policies. Other subjects on which the WCCF has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment in accordance with WCFF's Harassment/Discrimination Policy. This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.
- Protection from retaliation- The WCCF prohibits retaliation by or on behalf of the WCCF against Trustees, officers, employees, consultants, vendors, volunteers, other agents, and/or other recipients of funds from the WCCF, for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This protection extends to those whose allegations are made in good faith but prove to be mistaken. The WCCF reserves the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports or inquiries or who otherwise abuse this policy.
Where to report - Complaints, reports or inquiries may be made under this policy on a confidential or anonymous basis, in writing, to best allow them to be fully investigated. They should describe in as much detail as is known to the reporter the specific facts underlying the bases for the complaints, reports or inquiries: when and/or where the matter giving rise to the concern first occurred, whether it is continuing, the names of all those individuals involved in the matter, the names of other persons believed to have information relating to the matter, etc. Trustees, officers, employees, consultants, vendors, volunteers, other agents, and recipients of funds from the WCCF must recognize that the WCCF may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously. Complaints, reports or inquiries should be directed to the WCCF’s President and the Chairman of the Board of Trustees; if either of these persons is implicated in the complaint, report or inquiry, the complaint, report or inquiry shall be directed to another officer of the Board using the following sequence,: Vice Chairman, Treasurer, and Secretary. If both the President and Chairman of the Board of Trustees are implicated in the complaint, report or inquiry, notice shall be given to two other officers of the Board using the above detailed sequence. Within five business days of receipt, the recipient of the complaint, report or inquiry shall forward the matter directly to the Legal Committee. The initial recipient of the complaint, report or inquiry shall not himself/herself undertake any investigation into the matter, respond to it or discuss it with anyone. The Legal Committee shall be responsible for conducting a prompt, discreet, and objective investigation. Any member of the Legal Committee who is implicated in the complaint, report or inquiry shall recuse himself/herself from the investigation. The findings of the Legal Committee shall be reported in writing to the sender and to the Board. The Board shall maintain the confidentiality of the report, except as required by law.
Date of Adoption: October 22, 2020