Whistle Blower Policy

Can I call foul?

It is not required to establish a whistleblower policy in order to operate as a non-profit. However, this is another one of those Best Practices queries on the IRS form 990. Therefore, it is a good idea to understand what a whistleblower policy is, and to have such a policy in place.

An effective whistleblower policy allows employees and volunteers to report behaviors, policies or conduct which may be illegal, unethical, or in violation of some governing entity (i.e.: FCC), directly to the organization. Reciprocally, this allows the organization to learn of such violations or misconduct directly from the employers or volunteers, first, rather than from an outside source.

Policy Elements

An effective Whistleblower policy statement should contain the following:

1. A clear statement that all employees and volunteers are encouraged to report any suspected misconduct within the organization.
2. A notice to employees that they shall have no expectations of retaliation for any such report.
3. A determination of how and to whom such reporting should take place.
4. Procedures for investigating reports of misconduct.
5. Procedures for reporting to law enforcement and/or governing agencies should a determination be made that the allegations were legitimate.
6. And, clearly articulated possible consequences for those employees or volunteers found to have participated in misconduct.

A well written and implemented Whistleblower policy will allow for the organization to operate in an honest and transparent manner which benefits the entire apostolate. Additionally, having internal oversight into practices creates an even more credible face to donors and the community.