PURPOSE

Hands and Feet Project requires directors, officers, 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 Hands and Feet Project, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

REPORTING RESPONSIBILITY

The Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Hands and Feet Project 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 Hands and Feet Projects code of ethics or suspected violations of law or regulations that govern operations of Hands and Feet Project.

NO RETALIATION

It is contrary to the values of Hands and Feet Project 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 Hands and Feet Project. 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.

REPORTING PROCEDURE

Hands and Feet Project has an open-door policy and suggests that employees 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 the response of your supervisor, you are encouraged to speak with the Executive Director or a board member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Executive Director of Hands and Feet Project who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director.

COMPLIANCE OFFICER – EXECUTIVE DIRECTOR

The Executive Director of Hands and Feet Project is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. They will advise the Board of Directors of all complaints and their resolution and will report at least annually to the Board Chair on compliance activity relating to accounting or alleged financial improprieties.

ACCOUNTING AND AUDITING MATTERS

The Hands and Feet Project’s Executive Director shall immediately notify the Board Treasurer of any concerns or complaint regarding corporate accounting practices, internal controls or auditing, and work with the committee until the matter is resolved.

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.

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.

HANDLING OF REPORTED VIOLATIONS

The Executive Director of Hands and Feet Project 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.

*Note: The Compliance Officer may be a board member, the Executive Director, or a third party designated by the organization to receive, investigate and respond to complaints.