Whistleblower Policy
Blind Children’s Center is committed to operating in furtherance of its tax-exempt purposes and in compliance with all applicable laws, rules and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its board members, officers, employees, or volunteers. This policy outlines a procedure for employees to report actions that an employee reasonably believes violates a law, or regulation or that constitutes fraudulent accounting or other practices. This policy applies to any matter which is related to Blind Children’s Center’s business and does not relate to private acts of an individual not connected to the business of Blind Children’s Center.
If an employee has a reasonable belief that another employee or the Blind Children’s Center has engaged in any action that violates any applicable law, or regulation, including those concerning accounting and auditing, or constitutes a fraudulent practice, the employee is expected to immediately report such information to the Executive Director. If the employee does not feel comfortable reporting the information to the Executive Director, he or she is expected to report the information to the Assistant Executive Director.
All reports will be followed up promptly, and an investigation conducted. In conducting its investigations, Blind Children’s Center will strive to keep the identity of the complaining individual as confidential as possible, while conducting an adequate review and investigation.
Blind Children’s Center will not retaliate against an employee in the terms and conditions of employment because that employee: (a) reports to a supervisor, to the Executive Director, the Board of Directors or to a federal, state or local agency what the employee believes in good faith to be a violation of the law; or (b) participates in good faith in any resulting investigation or proceeding, or (c) exercises his or her rights under any state or federal law(s) or regulation(s) to pursue a claim or take legal action to protect the employee’s rights.
Blind Children’s Center may take disciplinary action (up to and including termination) against an employee who in management’s assessment has engaged in retaliatory conduct in violation of this policy.
In addition, Blind Children’s Center will not, with the intent to retaliate, take any action harmful to any employee who has provided to law enforcement personnel or a court truthful information relating to the commission or possible commission by Blind Children’s Center or any of its employees of a violation of any applicable law or regulation. Supervisors will be trained on this policy and Blind Children’s Center’s prohibition against retaliation in accordance with this policy.
Adopted: 11-17-14
Process for Determining CEO Compensation
Compensation for the Executive Director (CEO) of the Blind Children’s Center is determined by the organization’s Board of Directors, based upon the incumbent’s experience and track record of success, as well as a comprehensive survey of peer salaries at similar-sized nonprofits in similar economic markets.
Records Retention & Destruction Policy
It is the policy of the Blind Children’s Center that its records be retained only so long as they are (1) necessary to the current conduct of the Center’s business; (2) required to be retained by statute or government regulation; or (3) relevant to pending or foreseeable investigations or litigation. In furtherance of this policy, the Center has adopted the attached Record Retention Schedule and the following principles and procedures for its Record Management Program, which shall be strictly observed by the organization, its officers, Board of Directors, staff and committee members.
1. The responsibility for administering the Blind Children’s Center’s Record Management Program in accordance with this policy is designated to the Executive Director, who shall have the title Supervisor of Record Retention. In addition, the Supervisor of Record Retention, with the assistance of legal counsel, shall be responsible for an annual audit of the program.
2. Destruction of specific records shall be carried out only in accordance with the authority of the Supervisor of Record Retention.
3. All records, including those maintained on electronic data processing storage media, shall be covered by this policy.
4. Despite any retention periods specified in the attached Record Retention Schedule, all records shall be retained for at least the minimum period as stated in applicable state or federal laws or regulations. Once the period for office retention of records has passed, a determination will need to be made whether the records fall under the Archives Policy and should be transferred there.
5. The destruction of records shall be suspended immediately upon receipt of legal process or other notice of pending or foreseeable investigations or litigation, whether government or private. In addition, upon such notice, all of the Center’s records shall be secured immediately in order to prevent deliberate destruction of documents. No such suspension of the Center’s Record Management Program shall be lifted except upon the written authorization of legal counsel.
6. Requests for exemptions from the Program should be submitted to the Executive Director and legal counsel. Exemptions will be given only in accordance with the basic objectives of this Policy Statement.
7. The Executive Director, with the assistance of legal counsel, shall be responsible for interpreting this Policy Statement for application to specific situations.
11-14-14