Whistleblower Policy - Sample

1 1 Definition: Onewho revealswrongdoing withinan organization tothe public or tothose in positionsof key element ofSarbanes Policy - SampleIntroduction[ORGANIZATION NAME] Code of Ethics and Conduct requires directors, officers andemployees to observe high standards of business and personal ethics in the conduct of theirduties and responsibilities. As employees and representatives of theOrganization, we must practice honesty and integrity in fulfilling ourresponsibilities and comply with all applicable laws and ResponsibilityIt is the responsibility of all directors, officers and employees to complywith the Code and to report violations or suspected violations in accordancewith this Whistleblower director, officer or employee who in good faith reports a violation of the Code shall sufferharassment, retaliation or adverse employment consequence.

2 An employee who retaliatesagainst someone who has reported a violation in good faith is subject to discipline up to andincluding termination of employment. This Whistleblower Policy is intended to encourage andenable employees and others to raise serious concerns within the Organization prior to seekingresolution outside the ViolationsThe Code addresses the Organization s open door Policy and suggests that employees share theirquestions, concerns, suggestions or complaints with someone who can address them properly. Inmost cases, an employee s supervisor is in the best position to address an area of , if you are not comfortable speaking with your supervisor or you are not satisfied withyour supervisor s response, you are encouraged to speak with someone in the Human ResourcesDepartment or anyone in management whom you are comfortable in approaching.

3 Supervisorsand managers are required to report suspected violations of the Code of Conduct to theOrganization s Compliance Officer, who has specific and exclusive responsibility to investigateall reported violations. For suspected fraud, or when you are not satisfied or uncomfortable withfollowing the Organization s open door Policy , individuals should contact the Organization sCompliance Officer Officer1 The Organization s Compliance Officer is responsible for investigating and resolving allreported complaints and allegations concerning violations of the Code and, at his discretion, shalladvise the Executive Director and/or the audit committee. The Compliance Officer has directaccess to the audit committee of the board of directors and is required to report to the auditcommittee at least annually on compliance activity.

4 The Organization s Compliance Officer isthe chair of the audit and Auditing MattersThe audit committee of the board of directors shall address all reported concerns or complaintsregarding corporate accounting practices, internal controls or auditing. The Compliance Officershall immediately notify the audit committee of any such complaint and work with thecommittee until the matter is in Good FaithAnyone filing a complaint concerning a violation or suspected violation of the Code must beacting in good faith and have reasonable grounds for believing the information disclosedindicates a violation of the Code. Any allegations that prove not to be substantiated and whichprove to have been made maliciously or knowingly to be false will be viewed as a seriousdisciplinary or suspected violations may be submitted on a confidential basis by the complainantor may be submitted anonymously.

5 Reports of violations or suspected violations will be keptconfidential to the extent possible, consistent with the need to conduct an adequate of Reported ViolationsThe Compliance Officer will notify the sender and acknowledge receipt of the reported violationor suspected violation within five business days. All reports will be promptly investigated andappropriate corrective action will be taken if warranted by the Sample may used for non-commercial use by nonprofit organizations with the followingattribution: Copyright 2004, National Council of Nonprofit Associations, Sample NCNA 1 Note: Compliance officer could be a committee of the board, a designated director, or a third party such as an HRSpecialist or the board attorney (rch.)

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