Whistleblower Policy

PURPOSE
The purpose of this policy is to assist StrongMinds Inc. (Corporation) in preventing improper or potentially improper activities, encouraging Corporation Trustees, officers and other officials (Reporting Individuals) to report matters they believe to be material violations of law or policy or questionable accounting or auditing matters, providing for the documentation and resolution of any such report and protecting Reporting Individuals from retaliation.

REPORTING RESPONSIBILITY
Each Reporting Individual has an obligation to report what he or she believes is a material violation of law or policy or any questionable accounting or auditing matter by the Corporation, its officers, Trustees, employees, volunteers, agents or other representatives. The types of concerns that should be reported include but are not limited to any false or misleading information on the Corporation’s financial documents, grant reports, tax returns or other public documents; any instance of false information or materially incomplete information provided to the Corporation’s auditors, accountants, lawyers, Trustees or other representatives responsible for ensuring Corporation compliance with fiscal and legal responsibilities; embezzlement, private benefit or misappropriation of funds; material violation of Corporation policies; discrimination based on any prohibited category or category not relevant to the determination concerned; and facilitation or concealing any of the above or similar actions.

REPORTING PROCEDURE
Reporting Individuals should direct reports to an officer of the Corporation who is not involved in the concern or, if impractical, to one or more Trustees of the Board of Trustees of the Corporation. If reporting to an officer or Trustee is impractical, Reporting Individuals should direct reports to legal counsel for the Corporation. Board members can be reached by e-mailing confidential@strongminds.org.

HANDLING OF REPORTED VIOLATIONS
The Corporation will investigate all reports filed in accordance with this policy with due care and promptness. Matters reported internally without initial resolution will be investigated by the President of the Corporation and one or more disinterested individuals designated by the President to determine if the reports are accurate, whether the issues reported are material and what actions if any are necessary to address the issues. Investigations will be reported to the Board in a manner that respects confidentiality concerns to the extent practical.

AUTHORITY OF BOARD OF TRUSTEES OR BOARD COMMITTEE
The Board, or a committee of the Board, shall have full authority to investigate concerns raised in accordance with this policy if the Board determines that further investigation is required in light of the process described above. The Board may retain outside legal counsel, accountants, private investigators or any other resource that the Board reasonably believes is necessary to conduct a full and complete investigation of the allegations.

NO RETALIATION
This policy is intended to encourage and enable Reporting Individuals to raise serious concerns within the Corporation for investigation and appropriate action. With this goal in mind, no trustee, volunteer or employee who, in good faith, reports a concern shall be threatened, discriminated against or otherwise subject to retaliation or, in the case of an employee, adverse employment consequences as a result of such report. Moreover, a volunteer, including a Trustee or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.

ACTING IN GOOD FAITH
Anyone reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a violation of law or policy or a material accounting or auditing matter. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, with gross negligence or with the knowledge that the allegations are false will be viewed as a serious offense and may result in dismissal from the Reporting Individual’s volunteer position or termination of employment. Depending on the circumstances such conduct may also give rise to civil or criminal actions.

CONFIDENTIALITY
Reports of concerns and investigations related to them shall be kept confidential to the extent possible. Consistent with the need to conduct an adequate investigation, the Corporation cannot guarantee complete confidentiality. Whenever practical, disclosures of information shall be made only after written evaluation of the need to disclose by the President, Board of Trustees or committee conducting the investigation.

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