Whistleblower Policy

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.