Sustainable Economies Law Center requires board members and staff to observe high standards of business and personal ethics in the conduct of their duties. As representatives of the organization, and stewards of its mission, we must comply with applicable laws and hold each other accountable to practice honesty and integrity as we work toward our goals.

Reporting Responsibility

We encourage most conversations about workplace behavior and norm abidance to occur in peer-to-peer spaces and by using our conflict engagement process. Certain serious concerns, particularly those concerning financial matters and legal compliance, should be raised through this more formal channel. It is the responsibility of all staff members to use this Whistleblower process to report behaviors such as violations of law, misappropriation or misuse of funds, improper or undocumented financial transactions, other fraudulent matters, and activities creating a high likelihood of liability such as harassment, discrimination, slander, or intentional infliction of emotional distress. The following are examples of violations that should be reported using the process below. The list is not exclusive:

1. Stealing or misappropriation of the organization's funds, supplies, or other assets when amount is over $20 or behavior occurs on a repeated basis.
2. Fraud or deliberate error in the preparation, evaluation, review, or audit of any financial statement or accounting records.
3. Deviation from full and fair reporting of the Law Center's financial condition.
4. Deficiencies in or non-compliance with the Law Center's internal accounting controls.
5. Authorizing or receiving compensation for goods not received or services not performed.
6. Pursuit of a benefit or advantage in violation of conflict of interest policies.
7. Unauthorized alteration or manipulation of the corporation’s documents or computer files in violation of any of the corporation’s records management and retention policies.

No Retaliation

We encourage such reporting because it keeps us in line with the vision of our organization and enables us to operate more effectively and efficiently. It is entirely contrary to the character of the Law Center to retaliate against a person who chooses to report through professional or personal channels. To report in good faith is to demonstrate a commitment to the mission of the organization and a care for its continued success.

Acting in Good Faith

Most workplace concerns can be addressed through the conflict engagement process. The Whistleblower process is reserved for concerns that are legal or financial in nature. Anyone filing a written complaint concerning a violation or suspected violation must have reasonable grounds for believing a violation occurred. Any allegations that prove to have been made maliciously or baselessly will be considered a serious breach of policy and the ethos of teamwork.

Compliance Officer

The Board Secretary is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Secretary will advise the Board of Directors and members of appropriate Circles of all complaints and their resolution.

Reporting Procedure

The complaint must be written down so that it can be given to the Board Secretary directly by complainant. A staff member may ask another staff member to bring the report to the Secretary if they do not feel comfortable going directly to the Secretary. The document must contain the following information:

1. The rule you suspect is being violated
2. Type of behavior you observed
3. The dates you observed it
4. The people or Circles involved in this activity and what you believe to be their involvement
5. The names of anyone you think might have information about the activity
6. A description of who else you have spoken to about your suspicion
7. A statement that indicates whether you would like to remain confidential

Addressing the Complaint

The Board Secretary will:

1. Receive the complaint;
2. Screen it for materiality;
3. Analyze it to determine the best strategy to proceed;
4. Document the intended strategy on the complaint form;
5. Execute the strategy using the utmost discretion and in consultation with other stakeholders if appropriate;
6. Determine a resolution in consultation with the person who violated a policy and/or other affected parties when appropriate;
7. Record the resolution;
8. Report the resolution to the Board;
9. Report the resolution to the complainant; and
10. Maintain a permanent file of all complaints and their resolutions.

We value restorative processes and collaborative, generative responses in addressing problems such as these. The Board Secretary will preferably seek input from staff on how to address the complaint to ensure the response is in harmony with staff culture.

Accounting and Auditing Matters

Unless doing so might compromise any investigation of the complaint or cause backlash, the Board Secretary shall immediately notify the Finance Circle and the General Circle of any concerns regarding accounting practices, internal controls, or auditing and work with the Circles until the matter is resolved.

Confidentiality

Concerns may be submitted on a confidential basis. The identity of the person reporting the violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

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