Difference between revisions of "Whistleblower policy"
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| + | {{color bar header|title=Whistleblower Policy|toc=yes}} |
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| − | '''This is a draft policy''' |
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==ARTICLE I - PURPOSE== |
==ARTICLE I - PURPOSE== |
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| + | 1. <u>Purpose</u>. The purpose of this Whistleblower Policy ("Policy") is to describe the procedures through which concerns about illegal activity by or within Wikimedia District of Columbia may be raised and addressed. |
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| − | 1. <u>Purpose.</u> The Wiki Society of Washington, DC Inc. ("Society") requires directors, 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. |
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| + | 2. <u>No Retaliation</u>. No Wikimedia District of Columbia director, officer, employee, or volunteer shall |
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| + | engage in harassment or retaliation against any person who reports, in good faith, a violation of the law, or against any person who assists in the investigation of a reported violation. |
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| ⚫ | 3. <u>Good Faith</u>. Any person filing a complaint concerning suspected illegal activity must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law. Any allegations that prove to be unsubstantiated and to have been made maliciously or known to be false shall be treated as malfeasance and addressed accordingly. |
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| − | ==ARTICLE III - |
+ | ==ARTICLE III - REPORTING ALLEGED VIOLATIONS== |
| + | 1. <u>Reporting</u>. Reports concerning suspected illegal activity by or within Wikimedia District of Columbia shall be submitted to the President and the Vice President. If either is alleged to be acting in violation of the law, then the report shall be submitted to the Chair of the Audit Committee. |
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| − | 1. <u>No Retaliation.</u> No director, officer, employee, or volunteer, who in good faith reports 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 director 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 policy is intended to encourage and enable employees and others to raise concerns about illegal activity within the organization. |
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| ⚫ | 2. <u>Confidentiality</u>. Reports concerning suspected illegal activity may be submitted on a confidential basis. Reports and the names of sources will be kept confidential to the extent possible, except where necessary to conduct a complete and fair investigation, where required by law, or for review of Wikimedia District of Columbia operations by the Audit Committee. |
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| − | 1. <u>Reporting.</u> Officers, directors, and employees are expected to report suspected violations of Society policies or illegal activities to the President and the Vice-President. If either is alleged to be in violation of the law, then the report should be submitted to the Chair of the Audit Committee. A submitted report will be investigated by the Audit Committee with assistance from the President and Vice-President. If legal council is needed, it will be engaged at that time by the President. The Audit Committee is authorized to retain legal council to address a complaint if it involves the President or the Vice-President. A report of findings will be submitted to the Board of Directors with recommendations for action. |
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| ⚫ | 2. <u>Confidentiality |
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| ⚫ | 3. <u>Detail |
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| + | 1. <u>Responsibility for Investigation</u>. Reports of illegal activity shall be investigated by the Audit Committee with the assistance of the President and Vice President. |
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| + | 2. <u>Investigation</u>. Within five (5) business days of receiving a report of illegal activity, the Audit Committee shall acknowledge the complaint and begin an investigation. Upon completing a full investigation, the Audit Committee shall prepare a report of findings, together with recommendations for corrective action, and shall submit the report to the Board of Directors. |
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| − | ==ARTICLE V - ACCOUNTING AND AUDITING MATTERS== |
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| ⚫ | 1. <u>Accounting and Auditing |
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| + | 3. <u>Legal Assistance</u>. Outside legal counsel may be consulted as needed or warranted by the complaint. If assistance from legal counsel is required, it shall be engaged by the President at the time the complaint is received. The Audit Committee is authorized to retain legal counsel to address a complaint if it involves the President or the Vice President. |
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| − | ==ARTICLE VI - ACTING IN GOOD FAITH== |
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| − | ==ARTICLE |
+ | ==ARTICLE V - ACCOUNTING AND AUDITING== |
| ⚫ | 1. <u>Accounting and Auditing</u>. The Audit Committee shall address all reported concerns or complaints regarding accounting practices, internal controls, or auditing. The Chair of the Audit Committee shall immediately report to the President and Vice President if any improper accounting practices are reported by the independent auditors. The President and Vice President shall work with the Audit Committee until the matter is resolved. |
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| − | 1. <u>Notification and Investigation.</u> The appropriate person as outlined in this policy to receive an official complaint will notify the complainant and acknowledge receipt of the reported within 5 business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Outside legal council may be consulted as needed or warranted by the complaint. |
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| + | [[Category:Policies]] |
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| − | ==APPENDIX A - EXAMPLES OF ILLEGAL ACTIVITIES== |
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| − | The following is a non-exhaustive list of the kinds of activities that should be reported: |
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| − | * Supplying false or misleading information on the Society's financial or other public documents, including its Form 990. |
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| − | * Providing false information to or withholding material information from the Society’s independent auditors (if any). |
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| − | * Destroying, falsifying, or concealing any records that are official documents of the Society if the actions are in violation of the law. |
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| − | * Altering, destroying, or concealing a document, or attempting to do so, with the intent to impair the document’s availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations. |
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| − | *Embezzling Society funds or benefiting financially through association with the Society (for example, serving on the board and entering into a financially beneficial contract with the Society). |
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| − | * Paying for services or goods that are not rendered or delivered or "laundering" funds. |
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| − | * Using remarks or actions of a sexual nature that are not welcome and are likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual or particularly personal nature. |
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| − | * Using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, national origin, age, or disability. |
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| − | * Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, age, or disability. |
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| − | * Discriminating against an employee, grantee, potential employee or grantee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, physical or mental impairment, or veteran status. |
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| − | * Violating the Society’s Conflict of Interest Policy, Whistleblower Policy, or Document Retention & Destruction Policy. |
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| − | * Facilitating or concealing any of the above or similar actions. |
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Latest revision as of 19:32, 11 January 2014
ARTICLE I - PURPOSE
1. Purpose. The purpose of this Whistleblower Policy ("Policy") is to describe the procedures through which concerns about illegal activity by or within Wikimedia District of Columbia may be raised and addressed.
ARTICLE II - GENERAL PROVISIONS
1. Responsibility. All Wikimedia District of Columbia directors, officers, employees, and volunteers shall be responsible for reporting violations or suspected violations of the law in accordance with this Policy.
2. No Retaliation. No Wikimedia District of Columbia director, officer, employee, or volunteer shall engage in harassment or retaliation against any person who reports, in good faith, a violation of the law, or against any person who assists in the investigation of a reported violation.
3. Good Faith. Any person filing a complaint concerning suspected illegal activity must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law. Any allegations that prove to be unsubstantiated and to have been made maliciously or known to be false shall be treated as malfeasance and addressed accordingly.
ARTICLE III - REPORTING ALLEGED VIOLATIONS
1. Reporting. Reports concerning suspected illegal activity by or within Wikimedia District of Columbia shall be submitted to the President and the Vice President. If either is alleged to be acting in violation of the law, then the report shall be submitted to the Chair of the Audit Committee.
2. Confidentiality. Reports concerning suspected illegal activity may be submitted on a confidential basis. Reports and the names of sources will be kept confidential to the extent possible, except where necessary to conduct a complete and fair investigation, where required by law, or for review of Wikimedia District of Columbia operations by the Audit Committee.
3. Detail. For a proper investigation to be conducted, as much information as possible should be reported. The report should clearly describe the specific act or acts alleged to be in violation of the law and provide dates and names of individuals involved.
ARTICLE IV - HANDLING OF REPORTED VIOLATIONS
1. Responsibility for Investigation. Reports of illegal activity shall be investigated by the Audit Committee with the assistance of the President and Vice President.
2. Investigation. Within five (5) business days of receiving a report of illegal activity, the Audit Committee shall acknowledge the complaint and begin an investigation. Upon completing a full investigation, the Audit Committee shall prepare a report of findings, together with recommendations for corrective action, and shall submit the report to the Board of Directors.
3. Legal Assistance. Outside legal counsel may be consulted as needed or warranted by the complaint. If assistance from legal counsel is required, it shall be engaged by the President at the time the complaint is received. The Audit Committee is authorized to retain legal counsel to address a complaint if it involves the President or the Vice President.
ARTICLE V - ACCOUNTING AND AUDITING
1. Accounting and Auditing. The Audit Committee shall address all reported concerns or complaints regarding accounting practices, internal controls, or auditing. The Chair of the Audit Committee shall immediately report to the President and Vice President if any improper accounting practices are reported by the independent auditors. The President and Vice President shall work with the Audit Committee until the matter is resolved.