Whistleblower Protection Policy

Approved by the Board on March 11, 2023

Introduction

SFR requires directors, officers, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As 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, and volunteers to comply with SFR policies and to report violations or suspected violations of the law in accordance with this policy. It is also the responsibility of all directors and officers to familiarize themselves, and the teams or volunteers they manage, with this policy and its directives and requirements. In some cases, failure to report violations of the law may result in disciplinary action at the discretion of the Board.

No Retaliation

No director, officer, or volunteer, who in good faith reports a violation of the law or the bylaws or policies of Seattle Frontrunners, shall suffer harassment, retaliation, or adverse consequence of any kind even if the report is mistaken. The same shall be true for any individual who assists in the investigation of a reported violation. An officer, director, or volunteer who retaliates against someone who has reported a violation of the law in good faith is subject to disciplinary action up to and including removal from the organization. This Whistleblower Policy is intended to encourage and enable volunteers and members to raise concerns about illegal activity within the organization.

Reporting Alleged Violations

Officers, directors, and volunteers are expected to report suspected violations of SFR policies or illegal activities directly to the SFR President.  If the President is alleged to be in violation of the law, then the report should be submitted to the Vice President (or another officer if the President and Vice President are accused). A submitted report will be investigated by the Executive Committee of the Board (excluding any officer allegedly in violation of the law).  If legal counsel is needed, it will be engaged at that time by the President (or the officer handling the report in the event the President is accused, with the advice and consent of the Executive Committee of the Board).  A report of findings will be submitted to the full Board with recommendations for action.

Suspected illegal activity or suspected violations of SFR policies may be submitted on a confidential basis by the complainant. While the Board and its officers shall take all reasonable precautions to maintain confidentiality, confidential reports to the Board shall not provide a guarantee of anonymity. Reports will be kept confidential to the extent possible except to the extent necessary 1) to conduct a complete and fair investigation, or 2) for review of SFR operations by the Executive Committee and SFR’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 SFR policies. The report should outline a specific incident with dates and names of individual(s) involved, and any corroborating or exculpatory evidence that may exist. This report should be supplied in order to conduct a sufficient investigation.

Accounting and Auditing Matters

There shall be an Audit Committee formed to address all reported concerns or complaints regarding accounting practices, internal controls, or auditing. The Chair of the Audit Committee shall immediately report to the President if any illegal accounting practices are reported 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 SFR policies must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the law or SFR 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 report within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Outside legal counsel may be consulted as needed or warranted by the complaint. Complaints alleged or made outside of this manner shall not enjoy the protections outlined in this policy; however, the President or other appropriate officer shall endeavor to work with complainants to receive, notify and acknowledge complaints in the appropriate manner outlined by this policy if this is the case, upon which this policy shall apply.

Examples of Prohibited Activities

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

• Supplying false or misleading information on the SFR’s financial or other public documents, including its Form 990
• 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 SFR funds or benefiting financially through the organization by, 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 not welcome and are likely to be viewed as personally offensive, including sexual flirtations; 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 or particularly personal nature.
• Using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, national origin, age, or disability
• Circulating written or graphic material that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, age, or disability
• Violating SFR’s Conflict-of-Interest Policy or Whistleblower Policy
• Facilitating or concealing any of the above or similar actions