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Issues and Legislation
Connecticut Council for
Philanthropy
Whistleblower Policy
Policy regarding reporting of unlawful or
unethical behavior
As
beneficiaries of the public trust and stewards of a nonprofit legacy, the
Connecticut Council for Philanthropy should represent the pinnacle of sound
standards and practices. As such, the Council’s directors and staff must comply
with and frequently go beyond the laws and regulations applicable to nonprofit
organizations. This is especially true with regard to matters and controls that
affect the Council’s finances, audits, and governance. Directors and staff have
the responsibility to report any circumstance in which they have actual
knowledge that or a reasonable good faith belief that the Council’s internal
controls, auditing function, accounting systems or governance policies are
compromised or threatened.
The
Council board has adopted this Whistleblower Policy to address the submission by
directors, officers and staff members of complaints, concerns and suspected
violation with respect to one or more of the following matters:
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Questionable
accounting, internal accounting controls and auditing matters
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Compliance
with legal and regulatory requirements
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A violation or
suspected violation of the Council Code of Ethics
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Pursuit of a
benefit or advantage in violation of the Council’s conflict of interest policy
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A retaliatory
act against an employee who reports a suspected violation of any of the above
Reports
of such matters may be made to the president, and/or the board chair, and/or any
member of the Board Executive Committee. Whoever receives the report is required
to pass the information to the board chair. Reports can be made either in
writing or orally, but should contain enough information to substantiate the
concern and allow an appropriate investigation to begin. All reports will be
received and acted upon in confidence to the maximum extent possible given legal
requirements and the need to gather facts, conduct an effective investigation,
and take necessary corrective action.
Following investigation, the Council will take appropriate remedial and
disciplinary action as it deems justified by the circumstances, possibly
including termination of employment or removal from office, actions to seek
restitution or criminal prosecution.
No officer, director,
employee or agent of the Council shall take any harmful action with the intent
to retaliate against any person, including interference with employment or
livelihood, for providing to a law enforcement officer any truthful information
relating to a violation or suspected violation with respect to any of the
matters set forth above. Nor will any officer, director, employee or agent of
the Council take any harmful action with intent to retaliate against any
employee of the Council for reporting to the Council in the manner provided
above a violation or suspected violation with respect to any of the matters set
forth above. However, the Council may take action against a person who has
committed an offense even though they cooperated with the investigation or
against an individual who files a complaint without having reasonable belief in
the truth of the matters reported; in both cases such action may include
termination.
Adopted by the Board of
Directors September 2005
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