Whistleblower Policy

1. Purpose and Scope

This Whistleblower Policy establishes procedures for The Rory and Sully Project's employees, volunteers, board members, and contractors to report suspected violations of laws, regulations, organizational policies, or ethical standards without fear of retaliation or harassment.

This policy applies to all individuals associated with the Organization and covers suspected violations of:

• Federal, state, or local laws and regulations
• IRS regulations governing 501(c)(3) organizations
• Organizational policies and procedures
• Ethical standards and code of conduct
• Fraudulent financial reporting
• Misuse of organizational funds or assets
• Conflicts of interest
• Discrimination or harassment

2. Protected Disclosures

This policy protects good faith reports of suspected violations. A "protected disclosure" is information concerning any violation of law, regulation, or organizational policy, provided that the individual making the report has a reasonable belief that the information is true.

Good faith reports are those made with the honest belief that the information is accurate, regardless of whether it is ultimately proven to be correct.

3. How to Report Violations

Internal Reporting: Individuals who observe a suspected violation should first attempt to report it internally through the following channels:

• Direct supervisor or manager
• Executive Director
• Board Chair or Audit Committee
• Email: compliance@roryandsullyproject.org

Anonymous Reporting: Reports may be made anonymously through written communication to the Board Chair, provided sufficient detail is given to permit investigation.

External Reporting: If internal channels are unavailable or inappropriate, individuals may report to:

• Internal Revenue Service (IRS) at www.irs.gov
• State Attorney General
• Law enforcement agencies
• Regulatory agencies with jurisdiction over the conduct

4. Protection Against Retaliation

No employee, volunteer, board member, or contractor shall be subject to retaliation, discrimination, or harassment for:

• Making a good faith report of a suspected violation
• Cooperating with an investigation
• Refusing to participate in an illegal or unethical activity
• Providing truthful information in any hearing or proceeding

Retaliation includes but is not limited to: termination, demotion, suspension, threats, intimidation, harassment, or any adverse employment action.

Any person who violates this anti-retaliation provision will be subject to disciplinary action, up to and including termination.

5. Investigation Process

Upon receipt of a report, the Organization will:

• Acknowledge receipt of the report within 5 business days
• Conduct a prompt, fair, and impartial investigation
• Maintain confidentiality to the extent possible
• Document all findings and remedial actions
• Notify the reporting party of the investigation outcome (when appropriate)

Investigations will be conducted by internal staff or an external third party, depending on the nature of the alleged violation and any conflict of interest concerns.

6. Confidentiality

The Organization will maintain the confidentiality of the reporting individual to the extent permitted by law and investigation requirements. However, confidentiality cannot be guaranteed if:

• The identity is necessary to conduct a fair investigation
• Disclosure is required by law or legal process
• The individual gives consent to disclosure

7. Documentation and Records

All reports, investigations, findings, and remedial actions will be documented and retained in accordance with organizational record retention policies and applicable legal requirements. These records will be maintained securely and shared only with those with a legitimate business need.

8. False or Malicious Reports

While good faith reports of violations are protected, individuals who knowingly or recklessly make false accusations or fabricate evidence may be subject to disciplinary action. This protection does not extend to reports made with the knowledge that they are false or with reckless disregard for their truth.

9. Board Responsibility

The Board of Directors is responsible for:

• Overseeing the implementation and enforcement of this policy
• Receiving and investigating reports of violations
• Ensuring appropriate remedial action is taken
• Preventing retaliation against whistleblowers
• Reviewing this policy annually and updating as needed

10. Policy Review and Updates

This Whistleblower Policy will be reviewed annually by the Board and updated as necessary to reflect changes in applicable law or organizational practices. All employees, volunteers, and board members will be notified of any updates to this policy.

Contact Information

For questions or to report a suspected violation:

The Rory and Sully Project
Compliance Email: compliance@roryandsullyproject.org
Board Chair: [INSERT NAME AND CONTACT]
Website: www.roryandsullyproject.org