Whistleblower Protection Policy

In keeping with the policy of maintaining the highest standards of conduct and ethics, FIRST will investigate any suspected fraudulent or dishonest use or misuse of FIRST's resources or property by staff, board members, consultants, or volunteers. Staff, board members, consultants, and volunteers are encouraged to report suspected fraudulent or dishonest conduct (i.e., to act as "whistleblower"), pursuant to the procedures set forth below.

Reporting

A person's concerns about possible fraudulent or dishonest use or misuse of resources or property should be reported to a board member or the FIRST Secretariat. Alternately, to facilitate reporting of suspected violations where the reporter wishes to remain anonymous, a written statement may be submitted to one of the individuals listed above.

Definitions

Baseless Allegations

Allegations made with reckless disregard for their truth or falsity or allegations that were made maliciously or not in good faith. Individuals making such allegations may be subject to disciplinary action by FIRST and/or legal claims by individuals accused of such conduct.

Fraudulent or Dishonest Conduct

A deliberate act or failure to act with the intention of obtaining an unauthorized benefit. A non-exhaustive list of examples of such conduct include the following:

Whistleblower

An employee, consultant, or volunteer who informs a supervisor or the Chair about an activity relating to FIRST which that person believes to be fraudulent or dishonest.

Responsibilities and Investigations

Board Members and FIRST Secretariat

Board Members and the FIRST Secretariat are required to report suspected fraudulent or dishonest conduct to the Chair. Reasonable care should be taken in dealing with suspected misconduct to avoid

Due to the important, yet sensitive, nature of the suspected violations, effective professional follow-up is critical. Supervisors should not perform any investigative or other follow-up steps on their own. Accordingly, a supervisor who becomes aware of suspected misconduct should report it to the Chair, but should not without prior permission take steps on his or her own to do any of the following:

Investigation

All relevant matters, including suspected but unproved matters, will be reviewed and analyzed by an appropriate person designated by the Chair or the Board. This may include an investigation by legal counsel and/or accountants in some instances. All investigations will be kept confidential to the extent feasible. Appropriate corrective action will be taken, if necessary, and findings will be communicated to the reporting person and his or her supervisor.

Whistleblower Protection