A. Application. This Whistleblower Protection Policy applies to all

the Organization’s staff, whether full-time, part-time, or temporary

employees, to all volunteers, to all who provide contract services, and to all

officers and directors, each of whom shall be entitled to protection.

B. Reporting Credible Information. A protected person shall be

encouraged to report information relating to illegal practices or violations of

policies of the Organization that such person in good faith has reasonable

cause to believe is credible. Information shall be reported to the CEO (the

“Compliance Officer”), unless the report relates to the Compliance Officer,

in which case the report shall be made to the Board of Directors, or the

Oversight Committee.

Anyone reporting a Violation must act in good faith and have

reasonable grounds for believing that the information shared in the report

indicates that a Violation has occurred.

C. Investigating Information. The Compliance Officer shall promptly

investigate each report and prepare a written report for the Board of

Directors. In connection with such investigation, all people entitled to

protection shall provide the Compliance Officer with credible information.

All actions of the Compliance Officer in receiving and investigating the

report and additional information shall endeavor to protect the

confidentiality of all people entitled to protection.

D. Confidentiality

The Organization encourages anyone reporting a Violation to identify

himself or herself when making a report to facilitate the investigation of the

Violation. However, reports may be submitted anonymously by writing to

the Oversight Committee. Reports of Violations or suspected Violations will

be kept confidential to the extent possible, with the understanding that

confidentiality may not be maintained where identification is required by

law or to enable the Organization or law enforcement to conduct an adequate

investigation.

E. Protection from Retaliation. No person entitled to protection shall

be subjected to retaliation, intimidation, harassment, or other adverse action

for reporting information in accordance with this Policy. Any person entitled

to protection who believes that he or she is the subject of any form of

retaliation for such participation should immediately report the same as a

violation of and in accordance with this Policy.

Any individual within the Organization who retaliates against another

individual who has reported a Violation in good faith or who, in good faith,

has cooperated in the investigation of a Violation is subject to discipline,

including termination of employment or volunteer status.

F. Dissemination and Implementation of Policy. This Policy shall be

disseminated in writing via e-mail to all staff and board members in addition

the policy will be displayed on the organization’s website. The Organization

shall adopt procedures for implementation of this Policy, which may

include:

(1) documenting reported Violations;

(2) working with the Oversight Committee to decide whether the

reported Violation requires review by the Compliance Officer or

should be directed to another person or department;

(3) keeping the board of directors informed of the progress of the

investigation;

(4) interviewing employees;

(5) requesting and reviewing relevant documents, and/or requesting that

an auditor or counsel investigate the complaint; and

(6) preparing a written record of the reported violation and its disposition,

to be retained for a period of 7 years.

The Compliance Officer or the Oversight Committee shall communicate

with the complainant about the status of the complaint, to the extent that the

complainant’s identity is disclosed, at the conclusion of the investigation to

the extent consistent with any privacy or confidentiality limitations.