Whistleblower Policy

In keeping with the policy of maintaining high standards of conduct and ethics, the International House of Philadelphia will investigate any suspected fraudulent or dishonest use of IHP resources or property by staff, volunteers, consultants, and board members.

Staff, volunteers, consultants, and board members may report suspected fraudulent or dishonest conduct (i.e. act as a”whistleblower”), pursuant to the procedures set forth below.

A Whistleblower, as defined in this policy, is an employee and/or volunteer who reports an activity that he/she considers being illegal or dishonest to one or more of the parties specified in this policy.  The Whistleblower is not responsible for investigating the activity or for determining fault or corrective measures.

The International House of Philadelphia requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations and to report violations in accordance with this policy.

GUIDELINES:

No Retaliation

No employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. 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. This policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the organization.

Reporting Violations

The International House of Philadelphia has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his/her supervisor or is not satisfied with their supervisor’s response, the employee is encouraged to speak with a member of the management team and/or Executive Director. Supervisors and managers are required to report suspected violations to the Executive Director, who has specific and exclusive responsibility to investigate all reported violations. If an employee suspects any incidence of fraud, individuals should contact the Executive Director directly.  The improper activities may include, but not limited to:

• Misappropriation of funds
• Misleading financial information
• Failure to follow the intent of donor
• Misuse of organizational assets
• Fraud
• Coercion
• Any action that is in violation of any law, regulation or ordinance
• Conduct that is not honest and ethical
• Conflicts of interest
• Harassment
• Sexual Harassment

Acting in Good Faith

Anyone filing a 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.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Executive Director is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his/her discretion, shall advise the Board of Trustees.

The Executive Director will notify the sender and acknowledge receipt of the reported violation within 5 business days.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

In the event that a reported violation is made directly to the Board of Trustees, they will notify the sender and acknowledge receipt of the reported violation within 5 business days.  If warranted, the Board Chair will then convene a closed session meeting of the Executive Committee of the Board within 10 business days at a neutral location.  The purpose of the meeting will be to conduct an investigation of the violations and to determine if corrective action is warranted and, if so, what action will be taken.

As with all International House policies, any violation of the Whistleblower policy will be grounds for disciplinary action, up to and including termination

February 2, 2009