Whistleblower Policy

Introduction

Sing for Hope (“SFH”) requires its directors, officers, employees, Project Leaders, Artist Partners, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The purpose of this policy is to encourage and enable anyone working with SFH to report any action or suspected action taken within the organization that is illegal, fraudulent, or in violation of any adopted policy of the SFH to a source within SFH before turning to outside parties for resolution. This policy applies to any matter which is related to SFH’s business and does not relate to private acts of an individual not connected to the business of SFH.

A whistleblower, as defined by this policy, is an employee of SFH who reports an activity to designated officials that the employee considers to be an illegal or dishonest business activity. A whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples of Reportable Activities

Examples of illegal or dishonest activities include but are not limited to, violations of federal, state, or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.

Reporting Process and Protections

If you have knowledge of or concern about illegal or dishonest fraudulent activity, contact your supervisor, the COO, or a Co-Executive Director. Whistleblower protections are provided in two important areas: confidentiality and protection from retaliation against an employee who makes such a report. To the extent possible, the confidentiality of the whistleblower will be maintained. However, the whistleblower’s identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense. Additionally, SFH does not condone retaliation of any kind. A whistleblower who believes he/she has been retaliated against must contact the COO or a Co-Executive Director immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

Pursuant to the Defend Trade Secrets Act, an individual shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that: (A) is made (i) in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney; and (ii) solely for the purpose of reporting or investigating a suspected violation of law; or (B) is made in a complaint or other document that is filed in a lawsuit or other proceeding if such filing is made under seal. An individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the employer’s trade secret to the attorney of the individual and use the trade secret information in the court proceeding if the individual files any document containing the trade secret under seal; and does not disclose the trade secret, except pursuant to a court order.

Investigation Process

All reports of illegal and dishonest activities will be promptly submitted to the Co-Executive Directors, who are responsible for investigating and coordinating any corrective action needed.

If you have questions regarding this policy, contact the COO or a Co-Executive Director.