Purpose

The purpose of this document is to encourage employees and board members of RTNTX to raise concerns regarding suspected illegal or unethical conduct or practices, or violations of RTNTX policies on a confidential and, if desired, anonymous basis. The policy is to protect individuals from retaliation for raising such concerns.

Effective Date

This policy was made effective on December 26, 2023.

Stakeholders

Stakeholders for this policy:

Executive Director

Board of Directors

Table of Contents

Policy Statement        1

Definitions        2

Rights and Responsibilities        2

Managers and Supervisors        2

Whistleblower Protection        3

Policy Statement

Rebuilding Together North Texas (“RTNTX”) requires its board of directors, officers, employees, and volunteers to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of RTNTX must practice honesty and integrity in fulfilling the RTNTX mission and comply with all applicable laws and regulations.

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally concerning violations of RTNTX’s code of conduct or suspected violations of law or regulations that govern RTNTX operation so that RTNTX may address and correct any inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of RTNTX’s code of conduct or suspected violations of law or regulations that govern our operation.

No one may intimidate, harass, discriminate, or otherwise retaliate or in the case of an employee be subject to an adverse employment consequence, against any board member, officer, employee or volunteer who in good faith reports any action or suspected action taken by or within the corporation that is illegal, fraudulent, in violation of any adopted policy of RTNTX or a complaint of unlawful discrimination. 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. A board member who retaliates against someone who has reported a violation in good faith may be subject to removal from the Board.

RTNTX will investigate reported concerns and address any suspicious activities or behavior or suspected violation of law or RTNTX Policy by management, staff, volunteers, or members of the national organization. RTNTX will address and correct inappropriate conduct and actions. Anyone found to have violated any law or RTNTX Policy is subject to disciplinary action by RTNTX, up to and including civil or criminal prosecution when warranted.

Definitions

Baseless Allegations: allegations made with reckless disregard for their truth or falsity. People making such allegations may be subject to institutional disciplinary action and /or legal claims by individuals accused of such conduct.

RTNTX Policy: the policies set forth in corporation documents, board minutes or the staff handbook.

Whistleblower: an individual affiliated with the RTNTX including but not limited to an employee, Board member, volunteer, vendor, or client who submits a report in good faith of any concerns by informing their  manager, supervisor, the RTNTX Executive Director, or the President or Secretary of the Board of Directors about an activity which that person believes to be fraudulent or dishonest.

Rights and Responsibilities

Reporting Responsibility

Each individual has the responsibility to report in good faith any concerns about actual or suspected violations of RTNTX policies or any federal, state or municipal law or regulation governing RTNTX’s operations. Appropriate subjects to report under this policy include but are not limited to financial improprieties, account or audit matters, ethical violations, or other similar illegal or improper practices such as, fraud, theft, embezzlement, bribery or kickbacks, misuse of RTNTX assets or undisclosed conflict of interest.

Acting in Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of law and or ethical standards. Any unfounded allegation that proves to have been made maliciously, recklessly, or knowingly to be false will be viewed as a serious offense and result in disciplinary action up to and including termination of employment or volunteer status.

Managers and Supervisors

Managers or supervisors are required to report suspected fraudulent or dishonest conduct to the Executive Director or Secretary of the Board of Directors. In addition, managers or supervisors are responsible for maintaining a system of management controls, which detect and deter fraudulent or dishonest conduct. Failure by a manager or supervisor to establish management controls or report misconduct within the scope of this policy may result in adverse personnel action against the manager or supervisor, up to and including dismissal. The Executive Director is available to assist management in establishing management systems and recognizing improper conduct.

Reasonable care should be taken in dealing with suspected misconduct to avoid:

•        Baseless allegations.

•        Premature notice to persons suspected of misconduct and/or disclosure of suspected misconduct to others not involved with the investigation.

•        Violations of a person’s rights under law.

Accordingly, a manager or supervisor given notice of a suspected misconduct:

•        Should not contact the person suspected to further investigate the matter or demand restitution.

•        Should not discuss the case with anyone other than the Executive Director, the Secretary of the Board of Directors, the organization’s legal counsel, or a duly authorized law enforcement officer.

•        Should direct all inquiries from any attorney retained by the suspected individual to the organization’s legal counsel.

•        Should direct all inquiries from the media to the Executive Director or Secretary of the Board of Directors.

Whistleblower Protection

RTNTX encourages anyone reporting a concern to identify themselves in order to facilitate the investigation of the concern. However, concerns may be submitted on a confidential and/or anonymous basis. RTNTX will take reasonable steps to protect the identity of the whistleblower and keep reports of concerns confidential to the extent possible, consistent with the need to conduct an adequate investigation. RTNTX will use best efforts to protect whistleblowers against retaliation, as described below, although it cannot guarantee confidentiality.  RTNTX will keep the whistleblower’s identity confidential, unless (1) the person agrees to be identified; (2) identification is necessary to allow RTNTX or law enforcement officials to investigate or respond effectively to the report; (3) identification is required by law; or (4) the person accused of Fraud Policy violations is entitled to the information as a matter of legal right in disciplinary proceedings.

Whistleblowers must be cautious to avoid baseless allegations and anonymous allegations are discouraged so that there can be appropriate follow-up questions and investigation which may not be possible unless the source of the information is identified.

No Retaliation

Any individual who in good faith reports a concern or participates in a review or investigation of a concern shall be subject to harassment, retaliation, or in the case of an employee, adverse employment consequences because of such report or participation. This protection extends to individuals who report in good faith, even if the allegations are, after an investigation, not substantiated. 

Any individual who retaliates against someone who in good faith has reported or participated in a review or investigation of a concern will be subject to discipline, up to and including termination of employment or volunteer status.

RTNTX and all individuals affiliated with the organization may not retaliate against a whistleblower with the intent or effect of adversely affecting the terms or conditions of employment (including but not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary or wages). Whistleblowers who believe that they have been retaliated against may file a written complaint with the Secretary of the Board of Directors. A proven complaint of retaliation shall result in a proper remedy for the person harmed and the initiation of disciplinary action, up to and including dismissal, against the retaliating person. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.

Investigation and Reported Concerns

The Executive Director or Secretary of the Board of Directors (“Investigator”) shall administer the whistleblower policy. Any complaints about unethical or illegal conduct will be investigated. The Executive Director shall advise the Board of Directors of all complaints made under this policy and their resolution and will report at least annually to the Board Treasurer on compliance activity relating to accounting or alleged financial improprieties. The Executive Director shall immediately notify the Board Treasurer or Chair of the Board’s Finance committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the Board until the matter is resolved.

Anyone filing a writing 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. 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 a serious disciplinary offense.

Violations or suspected violations may be submitted on a confidential basis by the complainant.  Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. The reported information shall be maintained in a secure and locked location by either the Executive Director or the Secretary of the Board, together with any information collected or reports related to the investigation or resolution of the complaint.

The Investigator will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Any individual who is the subject of a complaint under this policy may not be present or participate in board or committee deliberations or vote on the matter relating to such complaint. However, such a person who is subject to the complaint may be asked to present information as background or answer questions at a committee or board meeting prior to the commencement of deliberations or voting relating thereto.

This policy shall be distributed to all directors, officers, employees and to volunteers who provide substantial services to RTNTX. The policy shall also be posted on RTNTX’s website and at RTNTX’s offices in a conspicuous location accessible to employees and volunteers.