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BRIC
Whistle Blower Policy

Revised November 2017

BRIC is committed to ethical, honest and legal practice in all aspects of our work, and to protecting those who report wrongdoing. This policy provides a way for directors, officers, employees and volunteers to raise good faith concerns about wrongdoing, and ensures that the concerns will be properly investigated.  A copy of this Policy will be distributed to all employees,and the policy will be posted on BRIC’s website.

Reporting

All directors, officers, employees and volunteers are covered under this Policy, and they may report any concerns about behavior by or within BRIC that appears to be illegal, fraudulent, dishonest, unethical or in violation of BRIC policy (a “Suspected Violation”). Examples of reportable activity include misuse of funds, fraudulent reporting or violations of the law.

The Executive Vice President of BRIC (the “Compliance Officer”) is responsible for investigating and overseeing the resolution of all reported complaints of Suspected Violations.  Anyone who is concerned about a Suspected Violation should report such concern, orally or in writing to the Compliance Officer.  If the Compliance Officer is the subject of the Suspected Violation, or for any reason, you are not comfortable reporting the Suspected Violation to the Compliance Officer or you are unsatisfied with the response, you should speak to your supervisor or someone in management with whom you feel comfortable.  In such case, he or she will submit the report to the Compliance Officer, unless the Compliance Officer is the subject of the complaint, in which case he or she will submit the complaint to the Audit Committee.  If the Compliance Officer is the subject of the complaint, the Audit Committee shall designate someone to act in the place of the Compliance Officer.Complaints of Suspected Violations may be made anonymously. Anonymous complaints should be detailed to the greatest extent possible because follow up questions will not be possible, making the investigation and resolution of such complaints difficult.   

All reports of Suspected Violations must be made in good faith and with reasonable grounds for concern. No investigation will be made of unspecified wrongdoing or broad allegations.  Anyone who intentionally or maliciously files a false report of wrongdoing will be subject to discipline, up to and including termination for staff members.

Note that reporting violations of BRIC’s personnel policies, including alleged employment discrimination, any type of unlawful harassment or complaints about supervisors or co-workers will be handled according to the procedures laid out in BRIC’s employee handbook.

Investigation

Any person who submits a complaint under this policy will be provided with an acknowledgement of receipt of his or her complaint within ten business days.  The Compliance Officer will ensure a prompt and full investigation of the allegations, determining fault and taking appropriate corrective action in an expeditious manner.  Depending on the severity or seriousness of the complaint, the Compliance Officer may consult with, or refer the matter to, the Board.  The person who is the subject of a complaint shall not be present at or participate in Board deliberations or vote on the matter relating to such complaint, provided that nothing shall prohibit the Board from requesting that the person who is subject to the complaint present information as background or answer questions at a Board meeting prior to the commencement of deliberations or voting relating thereto.  The result of an investigation will be reported to the Board Chair, who will determine what follow up is appropriate, including possible reporting to the full Board.  Records of all complaints shall be maintained in accordance with BRIC’s document retention policy.

Corrective action may include employee discipline up to and including termination, termination of board membership or volunteer status, seeking restitution, removal from office or pursuing criminal prosecution.

Confidentiality

As much as possible, confidentiality of the person reporting suspect behavior will be maintained. However, identity may have to be disclosed to conduct a thorough investigation and to comply with the law.

No Retaliation

BRIC will not retaliate against someone who reports a Suspected Violation or who cooperates with an investigation. This includes, but is not limited to, protection from harassment in any form, intimidation, discrimination, adverse employment consequences, disciplinary action, or re-assignment.  If you feel you have been retaliated against, report this immediately as discussed above, and it will be fully investigated.  Any person who retaliates against someone who reports a Suspected Violation in good faith is subject to appropriate discipline and corrective action, up to and including termination for a staff person.  The right of a whistleblower to protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

Notwithstanding the foregoing, in the event of any conflicting definitions between the New York Not-For-Profit Corporation Law (“NPCL”) and this Policy, the definitions under the NPCL will supersede and govern.