Whistleblower

Introduction

La Leche League International (LLLI) requires its representatives, both employees and volunteers, to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Representatives of LLLI must practice honesty and integrity in fulfilling their responsibilities, and must comply with LLL policy and all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage anyone who suspects that a participant in any LLLI department or activity has committed a financial infraction or violation of law to raise these concerns within the organization. The purpose of this policy to allow LLLI to correct internally any suspected violations of the financial procedures or laws that govern LLLI operations.

External systems of justice remain available should the complainant consider that making use of them is warranted.

Retaliation

No person will be discharged, threatened, or discriminated against in any manner for disclosing or threatening to disclose to an LLLI or LLL representative any activity, policy, or practice of LLLI that the person perceives to be violations of law and/ or other regulations.

Reporting Procedure

LLLI has an open-door policy and suggests that LLL and LLLI representatives share their questions, concerns, suggestions, or complaints with the LLLI Board. If the reporting person is not comfortable contacting the Board or is not satisfied with the Board’s response, then the reporting person must document the concern in writing and send the statement to the Executive Director, Chair of the LLLI Audit Committee, or Chair of the Board. If any of these persons is the subject of concern, the complainant should contact one of the above who is not involved, or another Board member if the Chair of the Board is the subject of the concern.

The Executive Director and Chair(s) of the Board are responsible for ensuring that all complaints about illegal conduct or financial impropriety are investigated and resolved.

Accounting and Auditing Matters

The Executive Director, the Chair of the Board, or the Treasurer of LLLI shall immediately notify the Audit Committee and the Board of Directors of any concerns or complaints regarding corporate accounting practices, internal controls, or auditing, and shall work with the committee until the matter is resolved.

Acting in Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a financial infraction or violation of law. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, with gross negligence, or with the foreknowledge that the allegations were false, will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be reported on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

Confirmation of receipt of the report should be made promptly to the complainant by the person handling the complaint. All reports will be investigated promptly, and appropriate corrective action will be taken if warranted by the investigation.

(Mar 09, rev Nov 12, Jan 14, July 20)