Software Freedom Conservancy Whistleblower Policy 1 Purpose Software Freedom Conservancy (“Conservancy”) intends to adhere to all laws and regulations that apply to the organization, and the underlying purpose of this Policy is to support Conservancy's goal of legal compliance. The support of all directors, officers, and staff members is necessary to achieving compliance with various laws and regulations. An employee is protected from retaliation only if the employee brings the alleged unlawful activity, policy, or practice to the attention of a Compliance Contact (currently [FIXME: insert name of Director] and provides the Compliance Contact with a reasonable opportunity to investigate and correct the alleged unlawful activity. The protection described below is only available to employees that comply with this requirement. 2 No Retaliation Conservancy will not retaliate against an employee who, in good faith, has made a protest or raised a complaint against some practice of a Conservancy supervisor, director, officer, or of another individual or entity with whom Conservancy had a business relationship, on the basis of a reasonable belief that the practice is in violation of law or a clear mandate of public policy. Conservancy will not retaliate against an employee who discloses or threatens to disclose to a supervisor or a public body any activity, policy, or practice of Conservancy that the employee reasonably believes is in violation of a law, or a rule, or regulation mandated pursuant to law or is in violation of a clear mandate or public policy concerning health, safety, welfare, or protection of the environment. 3 Acting In Good Faith Anyone filing a complaint concerning a violation or suspected violation of the ethical and legal standards noted above must act in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of such standards. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense. 4 Confidentiality Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. 5 Reporting Procedure Complaints may be filed by e-mail or in hard copy and may be submitted to either the Executive Director or to whistlereport@sfconservancy.org, which will be delivered to the Compliance Contact. Complaints relating to financial impropriety should be sent only to the Compliance Contact. The recipient of the complaint will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. 6 Notification Conservancy shall distribute this Policy to all employees and officers for their review. Every Conservancy employee and officer shall review the policy, and sign an Acknowledgment Form, attached hereto as Exhibit A. ----------------------------- Exhibit A: Conservancy Whistleblower Policy Acknowledgment Form My signature below indicates my receipt and understanding of the Software Freedom Conservancy Whistleblower Policy, incorporated herein by reference. I also verify that I have been provided with an opportunity to ask questions about the Policy. _____________________________ Employee Signature and date