DLC’s Grievance Policy

Introduction

This Policy is established to promote ethical behavior, transparency, and accountability at Dunes Learning Center (DLC). It provides a safe and confidential method for employees, volunteers, board members, contractors, and other stakeholders to report suspected misconduct, fraud, waste, abuse, or violations of organizational policies or applicable laws.

1. Purpose of the Policy

The purposes of this Whistleblower Policy are to:

  • Encourage reporting of suspected unethical or illegal conduct without fear of retaliation.

  • Ensure reports are handled promptly, professionally, and confidentially.

  • Protect individuals who make good-faith reports.

  • Provide clear procedures for reporting and investigating concerns.

  • Support compliance with federal, state, and local laws, as well as best practices for nonprofit governance.

2. Scope

This policy covers reports of concerns including, but not limited to:

  • Fraud, theft, or misuse of organizational assets

  • Misappropriation of grant funds or violations of grant requirements

  • Financial reporting irregularities

  • Conflicts of interest or unethical conduct

  • Violations of procurement policies

  • Harassment, discrimination, or abuse of authority

  • Violations of federal, state, or local laws

  • Dangers to public health or safety

  • Any conduct inconsistent with the organization’s mission, policies, or values

3. Reporting Responsibilities

All staff, volunteers, board members, and contractors have a responsibility to report suspected wrongdoing. Failure to report known misconduct may result in disciplinary action.

Reports may be made anonymously; however, individuals are encouraged to provide sufficient detail to allow for an effective investigation.

4. Reporting Procedures

Concerns may be reported through any of the following channels:

4.1 Immediate Supervisor or Manager

Employees may report concerns to their direct supervisor, unless the supervisor is involved in the alleged misconduct.

4.2 Executive Director

Reports may be submitted directly to the Executive Director (ED), except when the ED is involved in or connected to the conduct in question.

4.3 Board President or Executive Committee

If the concern involves senior leadership or financial misconduct, reports may be made directly to:

  • The Board President, or

  • Any member of the Executive Committee (President, Vice President, Treasurer, Secretary)

4.4 Confidential Reporting Channel

The organization will maintain a confidential reporting method, such as:

  • A dedicated email inbox accessible only to the Board President and Treasurer

  • A confidential phone voicemail line

  • Written reports placed in a secure lockbox accessible only to designated board officers

4.5 Anonymous Reporting

Anonymous reports are allowed. The organization will make every effort to investigate credible reports, even if the whistleblower’s identity is not known.

5. Confidentiality

The organization will maintain confidentiality to the fullest extent possible. Information will be shared only with individuals who need to know in order to:

  • Conduct a thorough investigation

  • Comply with legal obligations

Whistleblowers should understand that complete confidentiality cannot always be guaranteed.

6. Protection Against Retaliation

6.1 Non-Retaliation Commitment

The organization strictly prohibits retaliation against any individual who:

  • Makes a good-faith report of suspected misconduct, or

  • Participates in an investigation of such a report

6.2 Prohibited Acts of Retaliation

Retaliation may include, but is not limited to:

  • Termination or demotion

  • Reduction in hours or pay

  • Reassignment or exclusion from activities

  • Harassment or intimidation

  • Negative performance evaluations made for retaliatory reasons

Any individual who engages in retaliation will be subject to disciplinary action, up to and including termination or removal from the board.

6.3 False Reports

Reports made in bad faith, with knowledge of their falsity, may result in disciplinary action. Good-faith reports, even if unsubstantiated, are always protected.

7. Investigations

7.1 Initial Review

Reports will be reviewed by the appropriate party depending on the subject of the complaint:

  • Supervisors or ED for staff-related concerns

  • Executive Committee for concerns involving board members, senior leadership, or financial matters

7.2 Investigation Process

The assigned reviewer(s) will:

  • Conduct interviews and gather documentation

  • Maintain confidentiality and impartiality

  • Complete the investigation in a timely manner

  • Consult legal counsel as needed

7.3 Reporting Results

Findings will be documented and shared with:

  • The Executive Director (unless implicated)

  • The Executive Committee

  • The full Board when appropriate

Corrective actions will be implemented promptly.

8. Recordkeeping

The organization will retain whistleblower reports, investigation notes, findings, and follow-up actions for at least seven years. Access to records will be strictly limited.

9. Communication and Training

  • This policy will be distributed to all staff, volunteers, contractors, and board members.

  • New employees and board members will receive training on whistleblower protections.

  • The policy will be reviewed during annual compliance training.

10. Policy Review and Approval

The Governance Committee will review this policy at least every two years, or sooner if required by changes in law or best practices.

Any revisions must be approved by the Board of Directors.