Whistleblower Policy — DRAFT

Status: Draft. Counsel review required. Recommended by IRS Form 990 governance practices.

1. Purpose

Ganjier Guild requires directors, officers, employees, contractors, and volunteers to observe high standards of business and personal ethics. As employees and representatives of the Guild carry out their duties, they must practice honesty and integrity and comply with all applicable laws and regulations.

2. Reporting responsibility

It is the responsibility of all directors, officers, employees, contractors, and volunteers to report concerns about violations of the Guild's Code of Ethics, suspected violations of law or regulations that govern the Guild's operations, or any retaliation against a person who has reported in good faith.

3. No retaliation

No director, officer, employee, contractor, or volunteer who, in good faith, reports a concern shall be subject to retaliation, including (but not limited to) adverse employment consequences. A whistleblower who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination.

4. Reporting procedure

Concerns may be reported to:

• The chair of the Audit Committee (or, if none, the Treasurer)
• The Chair of the Board
• The third-party whistleblower service designated by the Guild

Reports may be submitted anonymously where permitted by law.

5. Handling of complaints

The Audit Committee (or designee) shall investigate and recommend corrective action. The committee shall report on each substantiated complaint to the full board.

6. Acting in good faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Allegations made in bad faith may result in discipline.

7. Confidentiality

Reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.