Whistleblower Policy

1. Purpose

The purpose of this Whistleblower Policy is to encourage directors, officers, employees, volunteers, and contractors of 23rd Veteran to report suspected misconduct, illegal activity, financial impropriety, or violations of organizational policy without fear of retaliation.

23rd Veteran is committed to conducting its operations with integrity, transparency, and accountability.

2. Scope

This policy applies to board members, officers, employees, volunteers, contractors, and consultants.

This policy covers reports of suspected fraud, theft, or financial misconduct; misuse of organizational funds or assets; violations of federal, state, or local laws; violations of organizational policies or bylaws; gross mismanagement or abuse of authority; retaliation against individuals who report concerns; and ethical violations or conflicts of interest not properly disclosed.

3. Reporting Concerns

Any individual covered by this policy is encouraged to report concerns as soon as possible.

Reports may be made to the Executive Director, Board Chair, Treasurer, or any member of the Board of Directors.

If the concern involves the Executive Director, the report should be made directly to the Board Chair or Treasurer.

Reports may be made verbally or in writing. Written reports are encouraged to ensure clarity and documentation.

Anonymous reports will be accepted to the extent permitted by law, though providing contact information may assist in a more thorough investigation.

4. No Retaliation

No director, officer, employee, volunteer, or contractor who in good faith reports a concern shall suffer harassment, retaliation, or adverse consequences.

Good faith means the individual reasonably believes the information reported is true, regardless of whether the investigation ultimately substantiates the concern.

Retaliation includes, but is not limited to termination or demotion; reduction in hours or compensation; harassment or intimidation; negative performance evaluations; threats or coercion.

Any person who retaliates against a whistleblower acting in good faith is subject to disciplinary action, up to and including removal from the board, termination of employment, or termination of contractual relationships.

5. Confidentiality

All reports will be handled as confidentially as possible, consistent with the need to conduct a thorough and fair investigation.

Information will be shared only with those who have a legitimate need to know.

6. Investigation of Reports

All reports shall be promptly reviewed and investigated.

The individual or body responsible for the investigation will depend on the nature of the complaint. Reports involving staff or volunteers may be handled by the Executive Director or a designated board member. Reports involving financial matters shall be reviewed by the Treasurer. Reports involving board members or the Executive Director shall be reviewed by the Board of Directors or a committee appointed by the board.

The organization will make reasonable efforts to investigate concerns promptly, fairly, and objectively.

7. Corrective Action

If an investigation confirms that misconduct has occurred, appropriate corrective action shall be taken.

Corrective action may include policy or procedural changes; disciplinary action; termination of employment or contracts; removal of board members; or referral to legal counsel or appropriate authorities when required.

8. False or Malicious Reports

Reports made in good faith will not result in adverse action, even if the investigation does not substantiate the concern.

Knowingly false, malicious, or reckless reports may result in disciplinary action.

9. Recordkeeping

The organization shall maintain records of reported concerns, investigations, and outcomes in a secure and confidential manner.

Access to these records shall be limited to authorized individuals.

10. Oversight and Board Responsibility

The Board of Directors has ultimate responsibility for ensuring this policy is followed and enforced.

The board shall receive periodic updates, as appropriate, regarding whistleblower reports and resolutions, while maintaining confidentiality.

11. Policy Distribution and Acknowledgment

This policy shall be provided to all directors, officers, employees, and volunteers.

All directors, officers, and key employees shall acknowledge in writing that they have received and understand the Whistleblower Policy.