Whistle​ ​Blower​ ​Policy| (modified​ ​April​ ​2017)

Article​ ​I:​ ​Purpose The whistle-blower policy is intended to provide a mechanism for the reporting of illegal activity or the misuse of PCRF assets while protecting the employee who make such reports from​ ​retaliation. Article​ ​II:​ ​Definition This policy is designed to address situations in which an employee suspects another employee has engaged in illegal acts or questionable conduct involving PCRF assets. This conduct might include outright theft (of equipment or cash), fraudulent expense reports, and misstatements of any accounts to any manager or to PCRF auditors or even an employee’s conflict of interest that results in financial harm to PCRF. PCRF encourages staff to report such questionable conduct and has established a system that allows them to do so while protecting their identity through the​ ​use​ ​of​ ​an​ ​online​ ​platform​ ​ ​run​ ​by​ ​a​ ​third​ ​party. Article​ ​III:​ ​Online​ ​Platform PCRF commissioned an independent consultant, SAANED for Philanthropy Advisory, to host an online platform for reporting questionable conducts or suggestions for improvements. All comments remain strictly confidential as they are only visible to SAANED. The whistle blower form requires the name to be mentioned in case SAANED needs to clarify the various issues being raised. The identity of the “whistle blower” will be protected when presenting issues to the Board of Directors and will only be revealed, if necessary, after the approval of the “whistle blower”. This online platform is available for staff to be accessed when the need arises where staff might have complaints or suggestions for making PCRF better. The Whistle Blower Platform can be accessed​ ​on​ ​the​ ​link​ ​provided​ ​in​ ​the​ ​personnel​ ​manual.

Article​ ​IV:​ ​Procedures If an employee suspects illegal conduct or conduct involving misuse of PCRF assets or in violation of the law, he or she may report it using the online platform and will be protected against any form of harassment, intimidation, discrimination or retaliation for making such a report​ ​of​ ​good​ ​faith. SAANED will raise issue with the PCRF Chairman of the Board. PCRF will promptly conduct an​ ​investigation​ ​into​ ​matters​ ​reported. Article​ ​V:​ ​Ensuring​ ​“No​ ​Retaliation” An employee who has made a report of suspicious conduct and who subsequently believes he or she has been subjected to retaliation of any kind by any PCRF employee is directed to immediately report it to the CEO or Board Chair as appropriate, or to SAANED on the online platform​ ​ ​if​ ​that​ ​provides​ ​ ​a​ ​safer​ ​place​ ​to​ ​report​ ​to. Reports of retaliation will be investigated promptly in a manner intended to protect confidentiality as much as practicable, consistent with a full and fair investigation. The party conducting​ ​the​ ​investigation​ ​will​ ​notify​ ​the​ ​employee​ ​of​ ​the​ ​result​ ​of​ ​the​ ​investigation. PCRF strongly disapproves of and will not tolerate any form of retaliation against employees who report concerns in good faith regarding PCRF operations. Any employee who engages in such retaliation will be subject to discipline up to and including termination. Likewise PCRF does not tolerate false accusation against staff or PCRF associates. Any employee who engages in​ ​such​ ​false​ ​accusation​ ​will​ ​be​ ​subject​ ​to​ ​discipline​ ​up​ ​to​ ​and​ ​including​ ​termination​.