Whistleblower Policy Template

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[Organization Name] — Whistleblower Policy

Effective [Effective Date] · Adopted by the Board of Directors on [Adoption Date]

1. Purpose and policy statement

[Organization Name] is committed to operating ethically and in compliance with the law. This policy encourages directors, officers, employees, volunteers, and contractors (collectively, “Covered Persons”) to report suspected violations of law, regulation, or organizational policy, and protects those who report in good faith from retaliation.

2. Protected disclosures

A report is protected under this policy when the Covered Person has reasonable cause to believe that the information discloses:

• a violation of a state or federal statute, rule, or regulation;
• non-compliance with a local, state, or federal rule or regulation; or
• unsafe work practices, financial irregularities, fraud, theft, or misuse of [Organization Name] resources.

Consistent with Cal. Lab. Code §1102.5, protection also covers Covered Persons who refuse to participate in an activity that would result in a violation of law or regulation, and those who are perceived to have made a protected disclosure.

3. Reporting channels

Covered Persons may report concerns through any of the following channels. No one is required to report through their immediate supervisor first.

• Internal — supervisor or management: raise the concern with your direct supervisor or any member of management.
• Board-level escalation: contact the [Audit Committee chair / designated board member] directly at [board-level contact email or address]. Use this channel if the concern involves management, finance, or if an internal report has not been addressed.
• External / governmental: Covered Persons may also report directly to a government or law enforcement agency, including the California Labor Commissioner, the California Attorney General, or any other agency with jurisdiction over the matter. Nothing in this policy restricts that right.

4. Anonymous reporting

Reports may be submitted anonymously. Anonymous reports should include as much specific information as possible so the matter can be investigated. [Organization Name] will treat all reports, including anonymous ones, as confidential to the extent consistent with a fair investigation and applicable law.

5. No retaliation

[Organization Name] prohibits retaliation against any Covered Person who, in good faith, makes or participates in a protected disclosure or refuses to participate in an activity that would result in a violation of law. Retaliation includes termination, demotion, discipline, harassment, threats, or any adverse change in terms or conditions of engagement. This protection applies whether a disclosure is made internally or to a government agency, and whether the Covered Person actually made the disclosure or is perceived to have made it. Any Covered Person who retaliates is subject to discipline, up to and including termination.

6. Investigation

Reports will be investigated promptly by the [Audit Committee / designated board member / independent investigator], who will take appropriate corrective action if the investigation substantiates a violation. The investigator will keep the reporter informed of the status of the investigation to the extent practical and consistent with confidentiality obligations.

7. Document retention

[Organization Name] will retain this policy, a record of each report received, and the investigation file for each report for the longer of the period required by the organization’s record-retention policy or seven (7) years after the matter is closed.

8. Distribution

A copy of this policy will be provided to every director, officer, employee, and regular volunteer of [Organization Name] upon engagement and whenever the policy is materially revised.

9. Adoption

Adopted by resolution of the Board of Directors of [Organization Name] on [Adoption Date].

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