Whistleblower Policy

Policy for the Detection and Reporting of Fraudulent Activity

The corporation requires employees or volunteers who reasonable believe that they are

aware of any violations of federal or state law such as fraud, inaccurate accounting

practices, or reporting of fraudulent financial information to disclose such violations,

without fear of retaliation, discrimination or harassment with respect to their

employment.

The following are examples of actions that should be reported:

-- Fraud or deliberate error in the preparation of any financial statement or accounting

records.

-- Deviation from full and fair reporting of the corporation&#39;s financial condition.

-- Stealing or misappropriation of the corporation or its donors&#39; funds or assets.

-- Deficiencies in or non-compliance with corporation&#39;s internal accounting controls.

-- Misrepresentations or false statements that constitute a violation of federal or state

law.

-- Violation of any federal or state law by the corporation.

The corporation strictly prohibits any retaliation against any employee, volunteer, board

member or donor who reports what he or she reasonably believes to be violations of

federal or state law. The corporation will not retaliate against any person who

participates in any investigation of such complaints. Conduct that is protected from

retaliation includes, but is not limited to:

(a) Providing information or otherwise assisting in an investigation regarding any

conduct that the employee, volunteer, board member or donor reasonable believes

constitutes a violation of federal or state law.

(b) Filing, testifying, participating in, or otherwise assisting an investigation, hearing,

court proceeding, or other administrative inquiry in relation to an alleged violation of

state of federal laws.

The corporation strictly prohibits any retaliation against any person on the basis that the

person provided truthful information to law enforcement relating to the violation or possible

violation of any law.

Report Procedure. Any person who becomes aware of any act or behavior described above is

encouraged to report as soon as possible to the board. Reports may be in writing or oral and

should include the details of the incident, the names of those involved, dates, and names of

any witnesses.

The corporation will investigate the complaint and endeavor to protect the privacy and

confidentiality of all parties involved consistent with corporation&#39;s obligation to comply with

applicable laws.

Non-Retaliation. Employees and non-employees (board members, donors, members,

volunteers) making reports or complaints under this policy will not be subject to any

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retaliation, discrimination or harassment. Prohibited retaliation includes firing, demotion,

suspension, harassment, failure to consider the employee for promotion, or any other kind of

discrimination against the employee in the terms and conditions of employment because of

the employee&#39;s involvement in protected activity.

Any employee who discourages or prevents other employees or persons from making reports

under this policy or participating n any investigation of such a report will be subject to

disciplinary action, up to and including termination.

Any complaint of acts or retaliation in relation to any reports made under this policy should

be submitted to the Board. The complaint will be promptly investigated. If a complaint is

substantiated, appropriate action will be taken.

Employees and non-employees (board members, donors, members, volunteers) are encouraged

to report to the Board any violation of federal or state law, any questionable accounting

or auditing matters, any reporting of fraudulent financial information, or retaliation

related to such reports. Nothing in this policy is intended to prevent an individual from

reporting information to a government agency when the person reasonably believes that

the corporation has violated any statute, rule or regulation.

The corporation may modify this policy at any time without notice to maintain

compliance with law.