Whistleblower Policy (v0.2 DRAFT)
Structural first-pass draft encouraging and protecting good-faith reporting of suspected illegal, unethical, or non-compliant conduct. For counsel review only.
Effective Date: DRAFT v0.2 — 2026-05-27 — NOT YET EFFECTIVEFirst-pass structural draft (v0.2) by Claude. Supersedes v0.1 placeholder. NOT effective. Markers: [CONFIRM], [TERM], [COUNSEL TO DRAFT].
Both entities are committed to integrity, lawful operation, and the [TERM] F.I.G.S. standard. This Policy establishes mechanisms by which directors, officers, employees, contractors, volunteers, Advisors, and Recipients may report concerns without fear of retaliation, consistent with federal whistleblower protections including Sarbanes-Oxley §1107 as applied to tax-exempt organizations [COUNSEL TO DRAFT].
Concerns may be reported through any of the following. Reports may be submitted in any language; reporters need not have proof, only a good-faith basis.
- Anonymous channel: [CONFIRM] an anonymous web intake hosted by [CONFIRM] an independent third-party service (e.g., a hotline provider) — to be selected before launch.
- Named channel: email to compliance@xerish.com, which routes to the audit/governance committee chair and to outside counsel.
- Direct to Board: any director may be contacted directly through the published Board contact at [CONFIRM].
A report is protected if made in good faith regarding suspected: (a) violation of law or regulation; (b) violation of Sponsor or SPC policy; (c) fraud, theft, embezzlement, or misappropriation of assets; (d) misuse of Grant funds; (e) financial-reporting irregularities; (f) safety concerns; (g) retaliation against another reporter; or (h) other matters a reasonable person would believe warrant attention.
No Covered Person or other reporter shall be subject to retaliation — including discharge, demotion, suspension, harassment, or adverse employment, contractual, or platform-account action — for making a good-faith report or for participating in an investigation. Retaliation is itself a violation of this Policy and is independently actionable.
The audit/governance committee (or designated independent investigator) shall conduct a prompt and impartial investigation of each report. The committee may engage outside counsel or independent investigators. The reporter will receive acknowledgment within [CONFIRM] 5 business days and, where feasible, a summary disposition within [CONFIRM] 60 days.
Reports and investigation materials shall be kept confidential to the extent consistent with conducting a thorough investigation and complying with applicable law. Anonymous reports will be respected; reporter identity (where known) will be disclosed only as necessary for the investigation or as required by law.
The audit/governance committee shall provide the full Board with an annual summary of reports received, dispositions, and any corrective actions taken. Identifying information about reporters shall be redacted.
Document Key: whistleblower_policy. Version: v0.2 (first-pass draft for counsel review). Draft Date: 2026-05-27. Effective Date: [CONFIRM] — none; this draft is not yet effective.