Sunday, April 24, 2011

Whistleblower Policy

THE MUSEUM OF FOOD IN AMERICA

WHISTLEBLOWER POLICY

I. Introduction

The Statement of Values and Code of Ethics adopted by THE MUSEUM OF FOOD IN AMERICA requires all staff, board members, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of THE MUSEUM OF FOOD IN AMERICA, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. Set forth below is THE MUSEUM OF FOOD IN AMERICA’s policy with respect to reporting good-faith concerns about the legality, propriety, or inappropriate nature of any plans or actions of, or on behalf of, THE MUSEUM OF FOOD IN AMERICA.

II. Reporting of Concerns or Complaints

It is the responsibility of all staff, board members, and volunteers to comply with THE MUSEUM OF FOOD IN AMERICA’s Code of Ethics and applicable law and to report violations or suspected violations in accordance with this Whistleblower Policy.

III. Confidentiality

THE MUSEUM OF FOOD IN AMERICA will treat all communications under this policy in a confidential manner, except to the extent necessary (1) to conduct a complete and fair investigation, (2) for review of THE MUSEUM OF FOOD IN AMERICA operations by THE MUSEUM OF FOOD IN AMERICA’s board, its audit committee, THE MUSEUM OF FOOD IN AMERICA’s independent public accountants, and THE MUSEUM OF FOOD IN AMERICA’s legal counsel, or (3) to respond to any compulsory process.

IV. Retaliation

THE MUSEUM OF FOOD IN AMERICA will not permit any negative or adverse actions to be taken against any employee or individual for making a good-faith report of a possible violation of its Code of Ethics or applicable law, even if the report is mistaken, or against any employee or individual who assists in the investigation of a reported violation. Retaliation in any form will not be tolerated. Any act of alleged retaliation should be reported immediately and will be promptly investigated. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise in good faith serious concerns within THE MUSEUM OF FOOD IN AMERICA prior to seeking resolution outside the organization.

V. How To Report Concerns or Complaints

Employees and others may communicate suspected violations of its Code of Ethics, applicable law, or other wrongdoing or alleged retaliation by contacting THE MUSEUM OF FOOD IN AMERICA’s counsel, [Name], of [Law Firm], [Address], [Phone Number]. If you wish to remain anonymous, it is not necessary that you give your name or position in any notification.

Whether or not you identify yourself, for a proper investigation to be conducted, please provide THE MUSEUM OF FOOD IN AMERICA with as much information as you can, sufficient to do a proper investigation, including where and when the incident occurred, names and titles of the individuals involved, and as much other detail as you can provide.

VI. Illustrative Types of Concerns

The following is a non-exhaustive list of the kinds of improprieties that should be reported:

Supplying false or misleading information on THE MUSEUM OF FOOD IN AMERICA’s financial or other public documents, including its Form 990.

Providing false information to or withholding material information from THE MUSEUM OF FOOD IN AMERICA’s board or auditors.

Destroying, altering, mutilating, concealing, covering up, falsifying, or making a false entry in any records that may be connected to an official proceeding, in violation of federal or state law or regulations.

Altering, destroying, or concealing a document, or attempting to do so, with the intent to impair the document’s availability for use in an official proceeding or otherwise obstructing, influencing, or impeding any official proceeding, in violation of federal or state law or regulations.

Embezzlement, theft, self-dealing, private inurement (i.e., THE MUSEUM OF FOOD IN AMERICA earnings inuring to the benefit of a director, officer, or senior management) and private benefit (i.e., THE MUSEUM OF FOOD IN AMERICA assets being used by anyone in the organization for personal gain or benefit)

Paying for services or goods that are not rendered or delivered.

Using remarks or actions of a sexual nature that are not welcome and are likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual or particularly personal nature.

Using epithets, slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, sexual orientation, national origin, age, or disability.

Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, sexual orientation, nationality, age, or disability.

Damaging or destroying property of THE MUSEUM OF FOOD IN AMERICA.

Compromising the privacy of donor lists or other confidential information of THE MUSEUM OF FOOD IN AMERICA.

Discriminating against an employee or potential employee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, physical or mental impairment, or veteran status.

Violating THE MUSEUM OF FOOD IN AMERICA’s Statement of Values and Code of Ethics, Conflict-of-Interest Policy, Harassment Policy, or Equal Employment Opportunity Policy.

Facilitating or concealing any of the above or similar actions.

VII. Questions

If you have any questions regarding this policy, please contact [Name], Director of Administration, at [Phone Number].

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