Whistleblower and Non-Retaliation Policy

(Adopted by a vote of the SEJ Board of Directors April 9, 2011)

Contents

I: General
II: Reporting Responsibility
III: No Retaliation
IV: Reporting Violations
V: Acting in Good Faith
VI: Confidentiality
VII: Handling of Reported Violations

I: General

SEJ requires directors, officers, 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 SEJ, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

II.      Reporting Responsibility

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

III.     No Retaliation

No director, officer, employee, volunteer, or contractor who in good faith reports a violation of SEJ policies, or law shall suffer harassment, retaliation or adverse employment consequence.

An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within SEJ prior to seeking resolution outside SEJ.

IV.    Reporting Violations

Directors, officers, employees, and volunteers should share their questions, concerns, suggestions or complaints with someone who can address them properly.

In most cases, employees and volunteers should report to the SEJ Executive Director.

However, if an employee or volunteer is not comfortable speaking with the Executive Director or is not satisfied with the response, that employee or volunteer is encouraged to report to any officer of the Board.

V.      Acting in Good Faith

Any good faith report, concern or complaint is fully protected by this policy, even if the report, question or concern is, after investigation, not substantiated.

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 SEJ policy, or law. Any allegations that prove not to be substantiated and have been made maliciously or with knowledge that they were false will be treated as a serious disciplinary offense.

VI.    Confidentiality

Upon the request of the complainant, SEJ will use its best efforts to protect the confidentiality of the complainant for any good faith report. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

VII.   Handling of Reported Violations

All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. The complainant will be informed that follow-up has or is occurring within two weeks after the Executive Director or board officer has received the complaint or report. The Executive Committee shall be informed of all such complaints or reports.

History of policy: Adopted by SEJ Board of Directors on this date: April 9, 2011

1 Based upon a sample Whistleblower policy Copyright 2004, National Council of Nonprofit Associations.

The National Council of Nonprofit Associations (NCNA) is the network of state and regional nonprofit associations serving over 22,000 members in 46 states and the District of Columbia. NCNA links local organizations to a national audience through state associations and helps small and mid- sized nonprofits: manage and lead more effectively; collaborate and exchange solutions; save money through group buying opportunities; engage in critical policy issues affecting the sector; and achieve greater impact in their communities.