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ROTARY CLUB OF STEAMBOAT SPRINGS
POLICY
POLICY NAME: Whistleblower
DATE APPROVED BY BOARD: February 10, 2025
EFFECTIVE DATE: February 10, 2025
NEXT SCHEDULED REVIEW DATE: February 2027
REPLACES POLICY DATED: March 8, 2021
PURPOSE: The Board of Directors has established a Whistleblower Policy to help eliminate wrongdoing by the representatives of Rotary Club of Steamboat Springs (RCSS).
POLICY STATEMENT:
The (RCSS) requires directors, officers and members 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. All members shall be made aware of this Whistleblower Policy.
The Board of Directors has established a Whistleblower Policy to help eliminate wrongdoing by the representatives of RCSS.
Reporting Responsibility
Each director, officer and member has an obligation to report in accordance with this Whistleblower Policy (a) questionable or improper accounting or auditing matters, and (b) violations and suspected violations of ethical conduct or conflicts of interest. This potential violation shall be called a “Concern”.
Reporting Channel
The reporting individual should provide a letter to a member of the Executive Committee as defined in the bylaws. The letter should be signed by the reporting member. If the reporting member is uncomfortable sending a signed letter, an unsigned letter will be accepted, but the investigation may be compromised without the ability to follow up with the complainant. The Executive Committee Member must discuss the Concern within ten (10) days with the Executive Committee at a meeting called for that purpose.
Exclusions from the Process
If the complaint identifies a member of the Executive Committee or Board of Directors, they will be excluded from all discussions and processes associated with an investigation if one occurs.
1. Acknowledgment and Receipt of Complaint
- Immediate Acknowledgment: Once a whistleblower complaint is received, it will be acknowledged promptly, ideally in writing, to assure the complainant that the issue is being taken seriously.
- Confidentiality Assurance: Inform the whistleblower about confidentiality measures to protect their identity and any details of the complaint, to the extent possible, during the process.
2. Initial Assessment of the Complaint
- Determine Validity: The Executive Committee will conduct a preliminary review to ensure that the complaint is valid, that it falls within the organization’s scope, and that it involves possible misconduct, such as fraud, harassment, corruption, or violations of internal policies.
- Identify Key Issues: Assess whether the complaint involves legal violations, ethical breaches, or potential policy infractions.
3. Conflict of Interest Check
- Appoint Independent Investigator: If the complaint is determined to be valid, ensure that the person assigned to investigate is unbiased and has no conflicts of interest with the parties involved in the complaint. This may be someone who is a Rotary club member or an outside party as determined by the Executive Committee.
- Create an Investigation Team: Depending on the complexity and nature of the complaint, an investigation team may be formed, including internal or external personnel, legal advisors.
4. Investigation Planning
- Scope Definition: Define the scope of the investigation, including the timeframe, the resources needed, and specific questions that need to be answered.
- Gather Evidence: Develop a plan to collect relevant evidence, including interviews with the complainant, witnesses, and individuals involved in the alleged misconduct, and review of documents or records.
5. Investigation Execution
- Conduct Interviews: Interview the whistleblower, alleged wrongdoers, and relevant witnesses to understand the full context of the complaint.
- Document Review: Examine any relevant documents, emails, reports, or financial records that may support or disprove the allegations.
- Preserve Confidentiality: Maintain confidentiality as much as possible throughout the investigation process to prevent retaliation and ensure integrity.
6. Analysis and Findings
- Evaluate Evidence: After collecting all the relevant information, the investigator(s) will assess the evidence, compare it with the organization's policies, and determine whether the allegations are substantiated.
- Report Drafting: The investigator(s) will prepare a report that outlines the findings, conclusions, and any recommendations for further action, which may include corrective measures or disciplinary action.
7. Decision Making
- Review of Findings: The investigative report should be reviewed by the Executive Committee.
- Determine Consequences: Based on the findings, decide on the appropriate action, which may include disciplinary actions, policy changes, or other corrective steps.
- Whistleblower Feedback: If possible, provide feedback to the whistleblower regarding the outcome of the investigation, ensuring that confidentiality is maintained.
8. Corrective Action and Remediation
- Implement Remedies: If the investigation finds that misconduct occurred, the Executive Committee will report its investigation and findings to the full board in Executive Session and provide its recommendations for action. The board will have the final determination of actions and will implement corrective actions to address the issue. This may include retraining, policy changes, or disciplinary actions against individuals involved.
Prevent Retaliation: Ensure that the whistleblower is protected from retaliation. If retaliation occurs, the organization should take immediate corrective action. This Whistleblower Policy is intended to encourage and enable directors, officers and members to raise Concerns within the Club for investigation and appropriate action. With this goal in mind, no director, officer or member who, in good faith, reports a Concern shall be subject to retaliation or retribution. Moreover, anyone who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including removal as a member of the Club.
9. Documentation and Reporting
- Complete Record Keeping: Keep detailed and secure records of the investigation process, findings, decisions, and any actions taken.
- Report to Stakeholders: If necessary, provide a summary report to the board of directors, funders, or regulatory bodies, depending on the nature and severity of the complaint.
10. Follow-up
- Monitor for Retaliation: Ensure that there is ongoing monitoring to ensure the whistleblower and others involved are not retaliated against.
- Evaluate Effectiveness: After the issue is resolved, evaluate the effectiveness of the investigation and any corrective actions taken to ensure that similar issues do not arise in the future.
11. Communication and Transparency
- Internal Communication: Share the outcome of the investigation with appropriate staff or stakeholders, while maintaining confidentiality and focusing on any necessary organizational changes or improvements.
Additional Assistance
The Executive Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the Concern.
Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation general ethics. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including removal as a member of the Club.