Whistleblower Policy

The Hampton Roads Community Foundation is committed to the principle of accountability, a piece of which provides for a systematic means for addressing good faith reports on allegations of misconduct. This policy outlines the system for receiving and responding to internal and external good faith reports about violations of the law, ethics, internal policy, or other misconduct of directors, employees, volunteers, or other foundation representatives. The policy also adheres to the “whistleblower” requirements of the National Standards for U.S. Community Foundations of the Community Foundations National Standards Board.

Code of Ethics

The foundation is committed to maintaining the highest standards of business and personal conduct. All directors, officers, volunteers, committee members, and employees must act with honesty and integrity in fulfilling their responsibilities on behalf of the Foundation and comply with all applicable laws and regulations.

  • If a policy, practice, or activity of the Foundation or its representatives is suspected to be fraudulent or dishonest conduct in violation of law or policy or generally accepted accounting practices, an individual must file a complaint in accordance with this Whistleblower Policy.
  • Anyone reporting a violation or suspected violation of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code. Any employee making allegations that cannot be substantiated and which prove to have been made maliciously or knowingly to be false is subject to discipline up to and including termination of employment.

Fraudulent or Dishonest Conduct

Fraudulent or dishonest conduct is a deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples of such conduct include, but are not limited to, the following:
  • Forgery or alteration of documents
  • Unauthorized alteration or manipulation of computer files
  • Fraudulent financial reporting
  • Embezzling, self-dealing, private inurement
  • Pursuit of a benefit in violation of the foundation’s Conflict of Interest Policy
  • Misappropriation or misuse of foundation resources such as funds, supplies, or other assets
  • Paying for goods or services that are not rendered or delivered
  • Authorizing or receiving compensation for goods not received, services not performed, or hours not worked
  • Facilitating or concealing any of the above or similar actions 
Material Violation of Foundation Policy

A material violation of foundation policy is a deliberate act or failure to act in accordance with established policies including but not limited to confidentiality, ethics, conflict of interest, whistleblower, and document retention.

Questionable Accounting or Business Practices  

Questionable accounting or auditing practices include, but are not limited to, the following:

  • Circumvention or attempted circumvention of accounting procedures or internal controls
  • Providing false information to or withholding material information from the Foundation’s auditors, lawyers, directors, or other representatives responsible for ensuring foundation compliance with fiscal and legal responsibilities 

Reporting Violations

If any foundation stakeholder as defined above reasonably suspects that some policy, practice, or activity of the Foundation is possibly fraudulent or dishonest conduct in violation of law, he/she may file a written or verbal complaint.

  • Employees should report their concerns about possible violations to their supervisors. However, if the concern involves the supervisor, or the employee is uncomfortable talking to the supervisor, he/she may report the concern directly to the Vice President for Administration, Chief Financial Officer, or, if need be, President. If the concern involves the President, the employee should report it to the Chair of the Board.
  • Directors and other volunteers may report their concerns about possible violations to the President, Chair of the Board, or Chair of the Audit and Finance Committee, whichever is deemed most appropriate to the concern.
  • Concerns may be submitted anonymously. However, there must be sufficient detail to allow for a full and fair investigation.

Confidentiality

The foundation keeps reports of suspected violations confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

All reported violations will be acknowledged within five business days by the official foundation recipient as delineated above, promptly investigated and, if warranted, acted upon with the appropriate corrective action. While some investigations might take longer than others, The foundation’s general practice is to conclude them as soon as practical without compromising the integrity and thoroughness of the necessary investigation. Unless the reported violation is against the President, he/she will be promptly notified of all reported violations regardless of the official foundation recipient. The Chair of the Board and the Audit and Finance Committee will also be promptly notified and involved in any reported concerns or complaints that involve corporate accounting practices, internal controls, or auditing regardless of origin.

No Retaliation

Employees and others who in good faith report a violation of the Code shall not suffer harassment, retaliation, or adverse employment consequence. Any employee who believes that he or she has been retaliated against may file a written complaint with the Vice President for Administration which will be acknowledged within five (5) days and promptly investigated. 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.