Whistleblower Policy
- Purpose
The purpose of this policy is to encourage all employees, volunteers, directors and officers of District 4 Coalition (“D4C”), to disclose wrongdoing that may adversely impact the D4C, or D4C’s employees, volunteers, directors or officers. This policy also sets forth an investigative process for reported acts of wrongdoing and retaliation. Employees are strongly encouraged to discuss with supervisors, managers or other appropriate personnel when in doubt about the best and ethical course of action in a particular situation. This policy addresses the continuing commitment of D4C to integrity and ethical behavior by helping to foster and maintain an environment where employees, volunteers, directors and officers can act without fear of retaliation by establishing procedures for (1) the receipt, retention, and treatment of complaints received by D4C regarding accounting, internal control, auditing, or other important matters; and (2) the confidential, anonymous submission by employees, volunteers, directors and officers of D4C of concerns regarding questionable accounting, auditing, or other matters. - Reports of wrongdoing
Every employee, volunteer, director and officer is encouraged to report under this Policy any concerns about any D4C activities that they believe, in good faith, to be illegal, unethical, questionable, or contrary to D4C policies. These matters include, without limitation, violations of law; fraud, theft, or embezzlement; improper financial transactions or use of D4C assets; accounting, internal controls or auditing irregularities such as undocumented transactions or misleading financial reporting; kickbacks; improper concealment or destruction of D4C records; breach or alleged breach of data security or confidentiality protocols; tampering with databases or other information technology systems; harassment or discrimination; unsafe working conditions; and violations of D4C’s conflict of interest policy. An employee, volunteer, director or officer who becomes aware of any wrongdoing or suspected wrongdoing is encouraged to make a written report as soon as possible to the Executive Director. If the Executive Director is alleged to be involved in committing the wrongdoing or does not respond satisfactorily to the report, the wrongdoing should be reported to a Board officer. Acts of wrongdoing should be disclosed in writing. To the extent possible, the identity of any employee, volunteer, director or officer who reports pursuant to this policy shall not be revealed, unless doing so is required for a thorough and effective investigation - Treatment of reports
For each report made, an inquiry will be initiated to determine if the report can be substantiated or has merit. That inquiry will be made by such person or persons (the “Investigator”) designated by the Board of Directors to review the report of wrongdoing. The Investigator shall determine whether, in their reasonable judgment, a reasonable basis exists for commencing an investigation into the report of wrongdoing. If the Investigator concludes that there is a likelihood of wrongdoing, they shall promptly forward the report of wrongdoing to the Board of Directors along with the Investigator’s conclusion about the merits of the report of wrongdoing. The Board of Directors will investigate each matter reported and determine appropriate corrective or disciplinary action, if required. The Board of Directors may enlist employees of D4C and/or outside legal, accounting, or other advisors, as appropriate, to conduct any investigation of a report of wrongdoing. A confidential file for each report or complaint will be maintained for an appropriate time period. - Non-retaliation for reporting
D4C, or any person acting on behalf of D4C, will not discharge, demote, suspend, discipline, harass, discriminate, or otherwise retaliate against any employee, volunteer, officer or director or their family members. If an employee, volunteer, officer, or director believes that they have been subject to any such retaliation, discrimination or other adverse action by D4C, they should report such action as set out in Section 2. Any employee, officer or director who engages in such retaliation may be subject to disciplinary action, up to and including termination of employment or Board removal. - Relationship to Laws
This Policy is intended to supplement and not replace any applicable federal and state laws, or any contracts to which D4C is party, relating to harassment, discrimination, and personnel policies. - This policy was adopted by the Board of Directors on September 8th, 2025