Introduction

This Whistleblower Policy is intended to encourage and enable employees and others associated with the organization to raise serious concerns within Achieve Now prior to seeking resolution outside the organization. Set forth below is Achieve Now’s policy with respect to reporting good-faith concerns about the legality or propriety of Achieve Now actions or plans.

Reporting of Concerns or Complaints

It is the responsibility of all staff, board members, and volunteers to comply with Achieve Now’s Code of Ethics and applicable law and to report violations or suspected violations in accordance with this Whistleblower Policy.

Confidentiality

Achieve Now will treat all communications under this policy in a confidential manner, except to the extent necessary 1) to conduct a complete and fair investigation, or 2) for review of Achieve Now operations by Achieve Now’s board, its audit committee, Achieve Now’s independent public accountants, and Achieve Now’s legal counsel.

Reporting Concerns or Complaints

If an employee suspects illegal conduct or conduct involving misuse of Achieve Now assets or in violation of the law, he or she may report it, anonymously if the employee wishes, and will be protected against any form of harassment, intimidation, discrimination, or retaliation for making such a report in good faith. Whistleblowers must be cautious to avoid baseless allegations.

Employees can make a report to the Executive Director or, if the problem concerns the Executive Director, the Director of Programs and/ or Board Chair. The organization will promptly conduct an investigation into matters reported, keeping the informant’s identity as confidential as possible, consistent with our obligation to conduct a full and fair investigation.

Illustrative Types of Concerns

The following is a non-exhaustive list of the kinds of improprieties that should be reported:

• Supplying false or misleading information on Achieve Now’s financial or other public documents, including its Form 990

• Providing false information to or withholding material information from Achieve Now’s board or auditors

• Destroying, altering, mutilating, concealing, covering up, falsifying, or making a false entry in any records that may be connected to an official proceeding, in violation of federal or state law or regulations

• Altering, destroying, or concealing a document, or attempting to do so, with the intent to impair the document’s availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations

• Embezzling, self-dealing, private inurement (i.e., Achieve Now earnings inuring to the benefit of a director, officer, or senior management) and private benefit (i.e., Achieve Now assets being used by anyone in the organization for personal gain or benefit)

• Paying for services or goods that are not rendered or delivered

• Using remarks or actions of a sexual nature that are not welcome and are likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual or particularly personal nature

• Using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, national origin, age, or disability

• Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, age, or disability

• Discriminating against an employee or potential employee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, physical or mental impairment, or veteran status

• Violating Achieve Now’s Statement of Values and Code of Ethics, Conflict-of-Interest Policy, Harassment Policy, or Equal Employment Opportunity Policy

• Facilitating or concealing any of the above or similar actions

Whistleblower Protection

Achieve Now will use its best efforts to protect whistleblowers against retaliation. Whistleblowing complaints will be handled with sensitivity, discretion, and confidentiality to the extent allowed by the circumstances and the law. Generally, this means that whistleblower complaints will only be shared with those who have a need to know in order that Achieve Now can conduct an effective investigation; determine what action to take based on the results of any such investigation; and, in appropriate cases, inform law enforcement personnel of the case's details.

Should disciplinary or legal action be taken against a person or persons as a result of a whistleblower complaint, such persons may also have the right to know the identity of the whistleblower.

Employees, consultants, and volunteers of Achieve Now may not retaliate against a whistleblower for informing management about an activity that the person believes to be fraudulent or dishonest with the intent or effect of adversely affecting the terms or conditions of the whistleblower’s employment, including but not limited to: threats of physical harm; loss of job; punitive work assignments; or impact on salary or fees.

Whistleblowers who believe that they have been retaliated against should file a written complaint with the Executive Director. If the Executive Director is the source of the perceived retaliation, the whistleblower should file a complaint with the Director of Programs and/ or Board Chair. Any complaint of retaliation will be promptly investigated and appropriate corrective measures taken if the allegations of retaliation are substantiated. This protection from retaliation is not intended to prohibit supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.