NC-SWANA WHISTLEBLOWER PROTECTION POLICY ADM - 004 PURPOSE This Policy is intended to encourage and enable any person Member of this organization to raise serious concerns internally so that NC SWANA can address and correct inappropriate conduct and actions. SCOPE This Whistleblower Protection Policy applies to all persons associated with NC-SWANA whom shall be entitled to this protection. REPORTING RESPONSIBILITY It is the responsibility of all officers, directors, contract agents, and volunteers to report concerns about violations of NC SWANA’s code of ethics or suspected violations of law or regulations that govern NC SWANA’s operations. NO RETALIATION It is contrary to the values of NC SWANA for anyone to retaliate against any board member, officer, contract agent, or volunteer who in good faith reports an ethics violation, or a suspected violation of ethics, law, or regulation. A member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including removal of director or officer from the Board; termination of contract; and/or revocation of membership. REPORTING PROCEDURE NC SWANA has an open door policy and suggests that anyone associated with the organization share their questions, concerns, suggestions or complaints with someone in a position to address an area of concern; such as an officer or director of the Board of Directors. Concerns of inappropriate conduct and actions will be taken to the Executive Committee for review and potential action. The Chapter President will serve as the Organization’s Compliance Officer and has the responsibility to investigate all reported violations. For concerns directly related to an officer of the Executive Committee; that officer may be excused from discussions, investigations, and any actions arising from the findings of Page 1 of 3 the complaint. For suspected fraud, or if complainant is not satisfied that the complaint has been addressed properly, they should contact the Organization’s Compliance Officer Directly, in writing. COMPLAINCE OFFICER The NC SWANA Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Board of Directors of all complaints and their resolution and will report at least annually to the Treasurer on compliance activity relating to accounting or alleged financial improprieties. ACCOUNTING AND AUDITING MATTERS The Executive Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Executive Committee of any such complaint and work with the Committee until the matter is resolved. ACTING IN GOOD FAITH Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious offence. 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. HANDLING OF REPORTED VIOLATIONS The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within ten business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Page 2 of 3 APPROVAL: ________________________________________ ________________________ PRESIDENT DATE ________________________________________ _________________________ VICE PRESIDENT DATE ________________________________________ _________________________ SECRETARY DATE ________________________________________ _________________________ TREASURER DATE Page 3 of 3