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PSF Whistleblower Protection Policy

General

The PSF requires directors, other volunteers, contractors, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the organization must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

Application

This Whistleblower Protection Policy applies to all of 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 (“protected person”).

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

It is not considered a violation of the PSF’s confidentiality policy to share confidential information with government representatives for purposes of reporting any violation of the law in conformance with this policy.

Protection from Retaliation

No protected person shall be subject to retaliation, intimidation, harassment, discharge, or other adverse action because:

  1. The individual reports or is about to report a violation, unless the employee knows or has reason to know that the report is false; or
  2. The individual participates or is requested to participate in an investigation, hearing, or inquiry in connection with a violation; or
  3. The individual refuses to commit or assist in a violation.

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.

Reporting Credible Information

A protected person shall be encouraged to report information relating to illegal practices, fraudulent financial reporting, or violations of policies of the PSF (a “Violation”) that such person in good faith has reasonable cause to believe is credible. Information shall be reported to the Executive Director (the “Compliance Officer”), unless the report relates to the Compliance Officer, in which case the report shall be made to the Chair of the Board of Directors, which shall be responsible to provide an alternative procedure.

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.

Investigating Information

The Compliance Officer shall promptly investigate each report and prepare a written report to the Board of Directors. In connection with such investigation, all persons 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 persons entitled to protection.

Handling of Reported Violations

The PSF’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Records related to reported violations will be kept for a period of seven (7) years.

Dissemination of Policy

This Policy shall be posted on the PSF’s website and included in the employee handbook.