Adopted February 6, 2022
Summit Impact requires directors, other volunteers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of Summit Impact must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
The objectives of the Summit Impact Whistleblower Policy are to establish policies and procedures for:
The submission of concerns regarding violations of the law, violations of ethical conduct, and/or questionable financial, accounting, or audit matters by employees, directors, officers, and other stakeholders of the organization, on a confidential and anonymous basis.
The receipt, retention, and treatment of complaints received by the organization regarding accounting, internal controls, or auditing matters.
The protection of directors, volunteers and employees reporting concerns from retaliatory actions.
Reporting Responsibility: Each director, volunteer, and employee of Summit Impact has an obligation to report in accordance with this Whistleblower Policy (a) questionable or improper accounting or auditing matters, and (b) violations and suspected violations of the law or of ethical conduct (hereinafter collectively referred to as Concerns).
No Retaliation: This Whistleblower Policy is intended to encourage and enable directors, volunteers, and employees to raise Concerns within Summit Impact for investigation and appropriate action. With this goal in mind, no director, volunteer, or employee who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, a volunteer 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.
Reporting Concerns: Directors, officers, employees, and volunteers should share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, employees and volunteers should report to the Executive Director. However, if an employee or volunteer is not comfortable speaking with the Executive Director or is not satisfied with the response, that employee or volunteer is encouraged to report to any officer of the Board.
Concerns may also be submitted anonymously. Such anonymous Concerns should be in writing and sent directly to any officer of the Board.
Directors and officers should submit Concerns in writing directly to the Chair of the Board.
Handling of Reported Violations: All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. The complainant will be informed that follow-up has or is occurring within two weeks after the Executive Director or board officer has received the complaint or report. The Officers shall be informed of all such complaints or reports.
The Board has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
Acting in Good Faith: Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the Codes. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.
Confidentiality: Reports of Concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.