The Clan Campbell Society (North America) requires trustees, officers, volunteers, and employees to observe high standards of
business and personal ethics in the conduct of their duties and responsibilities. As representatives of the Clan Campbell Society (North America), we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
A whistleblower policy encourages officers, board members, leadership, and volunteers to report credible information regarding illegal practices or violations of organization policies and specifies that they will be protected from retaliation. This policy is a standard "best practice" for 501(c)(3) governance. A whistleblower policy for a 501(c)(3) fulfills three primary goals:
- It encourages individuals to report illegal or unethical practices.
- Guarantees protection from retaliation.
- Identifies specific reporting channels.
Clan Campbell Society (North America) Whistleblower Policy
Article I: Reporting Responsibility
This Whistleblower Policy is intended to encourage and enable volunteers, employees, or members and others to raise serious concerns internally so that Clan Campbell Society (North America) can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Clan Campbell Society (North America)’s code of ethics or suspected violations of law or regulations that govern Clan Campbell Society (North America)’s operations.
Article II: No Retaliation
It is contrary to the values of Clan Campbell Society (North America) for anyone to retaliate against any board member, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Clan Campbell Society (North America). Any officer, board member, volunteer, employee, or member who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including loss of office, termination of employment, and permanent expulsion from the Clan Campbell Society (North America).
Article III: Reporting Procedure
Clan Campbell Society (North America) has an open door policy and suggests that volunteers, employees, and members share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Society President, or a board member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Clan Campbell Society (North America)’s Compliance Officer, or designated person, or board member, who has the responsibility to investigate all reported complaints. Volunteers, employees, or members with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Society President or the organization’s Compliance Officer, or designated person.
Article IV: Compliance Officer
The Clan Campbell Society (North America)’s Compliance Officer, or designated person, is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Society Leadership, and the Board of Trustees of all complaints and their resolution and will report at least annually to the [Treasurer/Chair of the Finance Committee/Audit Committee] on compliance activity relating to accounting or alleged financial improprieties.
Article V: Accounting and Auditing Matters
The Clan Campbell Society (North America)'s Compliance Officer, or designated person, shall immediately notify the Audit Committee/Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.
Article VI: Acting in Good Faith
Anyone filing a written 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.
Article VII: Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Article VIII: Handling of Reported Violations
The Clan Campbell Society (North America)’s Compliance Officer, or designated person, will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.