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 EFFECTIVEDraft Notice
First-pass structural draft (v0.2). Supersedes v0.1 placeholder. NOT effective.
1. Purpose
Both entities are committed to integrity, lawful operation, and the 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.
2. Reporting Mechanisms
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: an anonymous web intake hosted by 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 (to be confirmed).
3. Protected Conduct
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.
4. Non-Retaliation
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.
5. Investigation Process
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 5 business days and, where feasible, a summary disposition within 60 days.
6. Confidentiality
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.
7. Annual Review of Reports
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.
8. Effective Date + Version
Document Key: whistleblower_policy. Version: v0.2 (first-pass draft for counsel review). Draft Date: 2026-05-27. Effective Date: none; this draft is not yet effective.