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Whistleblower Policy: Reporting Suspected Violations of Law and Policy
Policy
The Nature Conservancy is committed to maintaining a workplace where employees are free to raise good faith concerns regarding the Conservancy's business practices, specifically: (1) reporting suspected violations of law on the part of the Conservancy, including but not limited to federal laws and regulations; (2) providing truthful information in connection with an inquiry or investigation by a court, agency, law enforcement, or other governmental body; and (3) identifying potential violations of Conservancy policy, specifically the policies contained in The Nature Conservancy's Policies and Procedures Manual.
An employee who wishes to report a suspected violation of law or Conservancy policy may do so confidentially by contacting the Chief Ethics and Compliance Officer, the General Counsel, or the Managing Director of Human Resources, or anonymously by calling a "hotline," which is created solely for this purpose and is managed and staffed by an outside company in order to maintain the anonymity of the source. The hotline telephone number is posted on the home page of the Conservancy's intranet site and listed on the Worldwide Office telephone list.
The Conservancy expressly prohibits any form of retaliation, including harassment, intimidation, adverse employment actions, or any other form of retaliation, against employees who raise suspected violations of law, cooperate in inquiries or investigations, or identify potential violations of Conservancy policies. Any employee who engages in retaliation will be subject to discipline, up to and including termination.
Any employee who believes that he or she has been subjected to any form of retaliation as a result of reporting a suspected violation of law or policy should immediately report the retaliation to one of the following: the "hotline," the Chief Ethics and Compliance Officer, the General Counsel, the Managing Director of Human Resources, the employee's immediate supervisor, or a representative of the Human Resources Function. Supervisors, managers, and Human Resources staff who receive complaints of retaliation must immediately inform the Chief Ethics and Compliance Officer, the General Counsel, or the Managing Director of Human Resources.
Reports of suspected violations of law or policy and reports of retaliation will be investigated promptly and in a manner intended to protect confidentiality, consistent with a full and fair investigation. The Chief Ethics and Compliance Officer, the General Counsel, the Managing Director of Human Resources, and the Management Committee member representing the region or function to which the suspected violation of law or policy relates will conduct or designate other internal or external parties to conduct the investigations. The investigating parties will notify the concerned individuals of their findings directly, or indirectly through the outside company managing the hotline where appropriate, and prepare other reports as indicated by the circumstances. A summary of all such reports will be presented to the Audit Committee of the Board of Directors.
In the event that a report of a suspected violation of law or policy or retaliation involves an individual who reports to the Chief Ethics and Compliance Officer, to the General Counsel, to the Managing Director of Human Resources, to the Management Committee member representing the region or function to which the suspected violation of law or policy relates, or to staff who report directly to these four officials, then that official will not participate in the investigation and the three remaining officials or their designees will conduct the investigation.
Purpose
To provide a mechanism for employees to raise good faith concerns regarding suspected violations of law on the part of the Conservancy, to cooperate in an inquiry or investigation by a court, agency, law enforcement, or other governmental body, or to identify potential violations of Conservancy policy; and to protect employees who take such actions from retaliation.
Origin
Approved by the Board of Directors January 30, 2004.
