Highland Area Community Foundation Whistleblower Protection Policy

The Highland Area Community Foundation (hereinafter “HACF”) requires directors, officers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the HACF, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. 

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that HACF can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, and volunteers to report concerns about violations of HACF’s code of ethics or suspected violations of law or regulations that govern HACF’s operations. 

No Retaliation

It is contrary to the values of HACF for anyone to retaliate against any board member, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of HACF. An employee or board member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. 

Reporting Procedure

 HACF has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with the Executive Director. If you are not comfortable speaking with the Executive Director or you are not satisfied with the Executive Director’s response, you are encouraged to speak with any Board Member. Executive Director and Board Members are required to report complaints or concerns about suspected ethical and legal violations in writing to the HACF’s Legal Counsel Board Member who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director or the organization’s Legal Counsel Board Member.

Legal Counsel Board Member

The HACF’s Legal Counsel Board Member is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Legal Counsel Board Member will advise the Executive Director and/or the Board of Directors of all complaints and their resolution and will report at least annually to the Executive Committee on compliance activity relating to accounting or alleged financial improprieties. 

Accounting and Auditing Matters

 The HACF’s Legal Counsel Board Member shall immediately notify the Executive Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved. 

Acting in Good Faith

 Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense. 

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. 

Handling of Reported Violations

The HACF’s Legal Counsel Board Member will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. 

Highland Area Community Foundation

Whistleblower Protection Policy

Approved by the Board of Directors on February 20, 2024