Scavenger Hunt: Whistleblower Policy

Welcome to our basic document Scavenger Hunt! In this section we will ask you to find existing documents and policies your board of directors should have. If your board gives you a policy book at the start of your term or on an annual basis – awesome. If not, this is a great chance to find the following documents and policies and begin to compile a universal resource for your board and leadership staff. Today, we are focusing on Whistleblower Policy. 

Why have a Whistleblower Policy?

Federal law prohibits all corporations (including nonprofits) from retaliating against employees who “blow the whistle” on fraudulent practices regarding accounting practices or destruction of evidence. Not all states require nonprofits to have their own Whistleblower Policy (for example here is New York State’s policy), but it is recommended that your organization have some form of policy.

Broadened Definition

For nonprofits, a Whistleblower Policy often includes a broader definition than the accounting and recordkeeping regulations federally mandated. Nonprofit Whistleblower Policies often include organizational activities and operations in addition to paid staff, board members and volunteers, and is instituted to create an open and transparent environment.

A Whistleblower Policy clearly lays out:
  • Reporting responsibility (what to report)
  • Reporting procedure (how to report)
  • Statement of “no retaliation”
  • Investigation procedure and responsible parties
  • Confidentiality statement
  • Signed by (board member, staff person or volunteer)
  • Date signed
Here are a few examples of Whistleblower Policies:

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