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Whistleblower Protection Policy

Introduction

The Claremont Running Team (CRT) requires Directors, Officers, Contractors, Employees, and Volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all directors, officers, employees, and volunteers to comply with CRT policies and to report violations or suspected violations of the law in accordance with this policy. 

No Retaliation

No Director, Officer, Employee, or Volunteer, who in good faith reports a violation of the law, shall suffer harassment, retaliation, or adverse employment consequence even if the report is mistaken, or against any employee or individual who assists in the investigation of a reported violation.  An employee, officer or director who retaliates against someone who has reported a violation of the law in good faith is subject to disciplinary action up to and including termination or removal from the organization.  This Whistleblower Policy is intended to encourage and enable employees and others to raise concerns about illegal activity within the organization.

Reporting Alleged Violations

Officers, Directors, and Employees are expected to report suspected violations of CRT policies or illegal activities to the CRT President or Vice President.  If either is alleged to be in violation of the law, then the report should be submitted to the Chair of the Audit Committee.  A submitted report will be investigated by the Audit Committee with assistance from the President and Executive Director.  If legal council is needed, it will be engaged at that time by the Chairman of the Board or President.  The Audit Committee is authorized to retain legal counsel to address a complaint if it involves the President or the Executive Director.  A report of findings will be submitted to the Board with recommendations for action. 

Suspected illegal activity or suspected violations of CRT policies may be submitted on a confidential basis by the complainant.  Reports will be kept confidential to the extent possible except to the extent necessary 1) to provide information to the appropriate legal authorities, 2) conduct a complete and fair investigation, or 3) for review of CRT operations by the CRT Audit Committee, the CRT’s independent public auditor and the CRT’s legal counsel.

For a proper investigation to be conducted, as much information as possible should be reported and it should clearly outline the perceived illegal act or violation of CRT policies. The report should outline a specific incident with dates and names of individual(s) involved. This report should be supplied in order to make proper notifications or conduct a sufficient investigation.

Accounting and Auditing Matters

The Audit Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing.  The Chair of the Audit Committee shall immediately report to the CRT President if any illegal accounting practices are reported by the independent auditors, and will work with the Audit Committee until the matter is resolved.

Acting in Good Faith

Anyone filing a complaint concerning suspected illegal activity or a violation of CRT policies must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law or CRT policies.  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 malfeasance and addressed accordingly.

Handling of Reported Violations

The appropriate person as outlined in this policy to receive an official complaint will notify the complainant and acknowledge receipt of the reported within 5 business days.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Outside legal council may be consulted as needed or warranted by the complaint.

Examples of Illegal Activities: 

The following is a non-exhaustive list of the kinds of activities that should be reported: 

  • Supplying false or misleading information on the CRTs financial or other public documents, including its Form 990
  • Providing false information to or withholding material information from CRT independent auditors
  • Destroying, falsifying, or concealing any records that are official documents of the organization and if the actions are in violation of the law.
  • Altering, destroying, or concealing a document, or attempting to do so, with the intent to impair the document’s availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations
  • Embezzling CRT funds or benefiting financially through association with the CRT, for example serving on the board and entering into a financially beneficial contract with the organization
  • Paying for services or goods that are not rendered or delivered.  “Laundering” funds.
  • Using remarks or actions of a sexual nature that are likely to be viewed as personally offensive, including unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual nature.
  • Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, or age.
  • Discriminating against an employee or potential employee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, or veteran status
  • Violating CRT’s Conflict-of-Interest Policy, Whistleblower Policy, or Document Retention & Destruction Policy
  • Facilitating or concealing any of the above or similar actions.

Claremont Running Team is a 501(c)3 non-profit organization

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