Habitat for Humanity of Summit County, Inc.

Whistleblower/Anti-Retaliation Policy

This Whistleblower/Anti-Retaliation Policy of Habitat for Humanity of Summit County, Inc. (“Habitat”): (1) encourages staff and volunteers to come forward with credible information on Prohibited Practices or Violations of Law; (2) specifies that Habitat will protect the person from retaliation; and (3) identifies where such information can be reported.

1. Encouragement of reporting.

Habitat encourages complaints, reports or inquiries about Prohibited Practices or Violations of Law, including illegal or improper conduct by Habitat itself, by its leadership, or by others on its behalf. For purposes of this policy, “Violations of Law” means a violation of any state, federal or local law that Habitat has the authority to correct and the staff member or volunteer reasonably believes that the violation is: (i) a criminal offense that is likely to cause an imminent risk of physical harm to persons, (ii) a hazard to public health or safety, or (iii) a felony. For purposes of this policy, “Prohibited Practices” means conduct that a staff member or volunteer reasonably believes constitutes a serious violation of the policies and practices established by Habitat and that would financially or detrimentally impact Habitat, such as incorrect financial reporting, financial improprieties, accounting or audit matters, or detrimentally impact the reputation of Habitat, such as ethical violations, fraudulent conduct, or other similar improper practices or policies.

Other subjects on which Habitat has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment via Habitat’s human resources channels, unless those channels are themselves implicated in the wrongdoing. This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.

2. Protection from retaliation.

Habitat prohibits retaliation by or on behalf of Habitat against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This includes retaliation in the form of an adverse employment action such as termination, decrease in compensation, or the threat of physical harm. Every effort will be made to protect the confidentiality of the staff member or volunteer making the report. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense.

This protection extends to those whose allegations are made in good faith but prove to be mistaken. Habitat reserves the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports or inquiries or who otherwise abuse this policy. Any staff member or volunteer who makes a report under this policy who believes he or she is being retaliated against must immediately contact Habitat’s President and Chief Executive Officer or President of the Board of Trustees; if both of those persons are implicated in the complaint, report or inquiry, it should be directed to any member of the Board of Trustees not so implicated.

3. Where to report.

Subject to disclosure that may be necessary as described in Section 2 above, complaints, reports or inquiries may be made under this policy on a confidential or 2 anonymous basis. They should describe in detail the specific facts demonstrating the basis for the complaints, reports or inquiries. They should be directed to Habitat’s President and Chief Executive Officer or President of the Board of Trustees; if both of those persons are implicated in the complaint, report or inquiry, it should be directed to any member of the Board of Trustees not so implicated. Habitat will conduct a prompt, discreet, and objective review or investigation. Staff or volunteers must recognize that Habitat may be unable to fully evaluate a vague or general complaint, report or inquiry that is made anonymously.