Whistleblower Policy

Article I: General

  1. The Friends of MontanaPBS requires directors, officers, volunteers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Friends of MontanaPBS, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
  2. The objectives of the Friends of MontanaPBS Whistleblower Policy are to establish policies and procedures for:
    1. The submission of concerns regarding questionable accounting or auditing matters by employees, directors, officers and other stakeholders of this organization, on a confidential and anonymous basis.
    2. The receipt, retention and treatment of complaints received by the organization regarding accounting, internal controls or auditing matters.
    3. The protection of directors, volunteers and employees reporting concerns from retaliatory actions.

Article II: Policy

Section 1: Reporting Responsibility
It is the responsibility of all directors, officers, volunteers and employees to report ethics violations or suspected violations in accordance with this Whistleblower Policy.

Section 2: No Retaliation
No director, officer, volunteer or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. A volunteer or employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment. This Whistleblower Policy is intended to encourage and enable directors, volunteers and employees to raise serious concerns within the Friends of MontanaPBS for investigation and appropriate action.

Section 3: Reporting Violations
Employees should first discuss their concern with their immediate supervisor. However, if they are not comfortable speaking with their supervisor or are not satisfied with their supervisor’s response, the employee is encouraged to speak with the Chair of the Finance/Audit Committee. Directors and other volunteers should submit their concerns in writing directly to the Chair of the Finance/Audit Committee.

Section 4: Handling of Reported Violations

The Finance/Audit Committee shall address all reported concerns. The Chair of the Finance/Audit Committee shall immediately notify the Finance/Audit Committee and the Chair of the Board of Directors of any such report. The Chair of the Finance/Audit Committee will notify the sender and acknowledge receipt of the concern within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted concerns.

All reports will be promptly investigated by the Finance/Audit Committee, and appropriate corrective action will be recommended to the Board of Directors, if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the concern. The Finance/Audit Committee 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.

Section 5: Acting in Good Faith
Anyone filing a complaint concerning an improper accounting or auditing practice, or a 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, 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.

Section 6: 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. 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 dismissal from the volunteer position or termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

Last updated and approved by the Friends of MontanaPBS board on August 15th, 2014