Purpose
The Baltimore Council on Foreign Affairs (BCFA) is committed to maintaining a culture of
openness, accountability, and ethical conduct. This Whistleblower Policy is intended to provide
a mechanism for trustees, officers, employees, and volunteers to report, without fear of
retaliation, any concerns regarding illegal, unethical, or improper conduct related to BCFA’s
operations and governance.
Scope
This policy applies to all members of the Board of Trustees, officers, employees, and volunteers
of the BCFA. It is designed to encourage reporting of any suspected violations of laws,
regulations, BCFA policies, or ethical standards.
Definition of Reportable Violations
Reportable violations under this policy include, but are not limited to:
- Fraud: Any fraudulent activity, including financial misconduct, misappropriation of funds,
or falsification of records. - Legal Violations: Any activity that violates federal, state, or local laws or regulations.
- Ethical Violations: Conduct that breaches BCFA’s Code of Conduct, Conflict of Interest
Policy, or other ethical standards. - Safety Violations: Any action that endangers the health or safety of BCFA personnel,
members, or the public. - Retaliation: Any act of retaliation against an individual who, in good faith, reports a
concern or assists in an investigation.
Reporting Procedures
Reporting Procedures
- Reporting Channels: Concerns may be reported to the Chairman of the Board of
Trustees, the President, or any designated officer responsible for compliance and ethics. - Anonymous Reporting: While the BCFA encourages individuals to provide their names
when reporting, anonymous reports will also be accepted and investigated to the extent
possible. - Good Faith Requirement: Reports should be made in good faith with reasonable
grounds for believing that the reported information indicates a violation of law or policy.
Malicious or knowingly false reports may lead to disciplinary action.
Investigation Process
Investigation Process
- Review of Report: All reports will be reviewed promptly by the designated officer or a
Whistleblower Committee to determine the appropriate scope and course of the
investigation. - Confidentiality: To the fullest extent possible, the identity of the whistleblower will be
protected, consistent with the need to conduct a thorough investigation. - Documentation: A written record of the reported incident and investigative steps taken
shall be maintained in accordance with BCFA’s record-keeping policy.
Protection from Retaliation
The BCFA strictly prohibits any form of retaliation against any individual who, in good faith,
reports a concern or participates in an investigation. Retaliation includes adverse employment
actions, harassment, demotion, or discrimination. Individuals who believe they have been
subjected to retaliation should report this to the Board Chair, Executive Director, or designated
compliance officer.
Violations of this anti-retaliation provision may result in disciplinary action, up to and including
termination of employment or removal from the Board.
Annual Review and Training
The Whistleblower Policy shall be reviewed annually by the Board of Trustees to ensure its
effectiveness. Trustees and employees will receive annual training on the Whistleblower Policy,
including information on how to identify and report potential violations.
Policy Approval and Amendments
This Whistleblower Policy shall be approved by the Board of Trustees and may only be
amended by a majority vote of the Board.