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NEW CANAAN LAND CONSERVATION TRUST, INC.

Whistleblower Policy

Approved by the Board of Directors: February 16, 2017

I. PURPOSE

The purpose of the Whistleblower Policy is to provide a policy and procedure that encourages any New Canaan Land Trust (NCLT) employees or Board members to disclose unethical and illegal conduct in any aspect of NCLT operations, to describe methods to report such violations, and to protect individuals from retaliation.

II. CORE VALUES

The New Canaan Land Trust is committed to its Core Values, including ethical and lawful behavior in all of its activities. As such, NCLT requires any employee or Board member to observe high standards of business and personal ethics and act with honesty and integrity when conducting their duties and responsibilities on behalf of NCLT.

III. RESPONSIBILITIES AND REPORTING

Any employee or Board member should promptly report directly to the President, or if uncomfortable or inappropriate to discuss with the President, then report to the Executive Director or President, any of the following situations of which an employee or Board member becomes aware or has reason to believe may exist:

  • Violations of any applicable federal, state or local law or regulation;
  • Violations of NCLT policy, including its Whistleblower Policy;
  • Questionable or improper matters regarding bookkeeping, accounting, internal accounting controls, or auditing matters;
  • Actions that threaten public health or safety; or
  • Inappropriate handling or resolution of any complaint or matter previously reported under this Policy.

Reports under this Policy will be taken seriously. The President is responsible for investigating and resolving all reported complaints and allegations of illegal and unethical conduct. Appropriate corrective action, up to and including termination of employment or removal from the Board of Directors, will be taken if warranted by the investigation into the reported conduct or for violations of this Policy.

IV. ACTING IN GOOD FAITH

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegation that proves not to be substantiated and which proves to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense, and may result in immediate removal from the Board of Directors or termination of employment.

V. NO RETALIATION

This Whistleblower Policy is intended to encourage and enable any employee or Board member to raise serious concerns within NCLT prior to seeking resolution outside the organization. A reasonable opportunity is given to NCLT to correct an action that is in violation of a law or regulation.

No employee or Board member who threatens to disclose, who in good faith reports a violation, or because of any lawful act, shall suffer harassment, retaliation, suspension, demotion, or other adverse employment consequence. Lawful acts include reporting violations in accordance with this policy, providing information to, or testifying before, any public body conducting an investigation, or refusing to participate in any activity that is a violation of the law.

Any employee or Board member who has reason to believe that he or she has been subject to retaliation for making a report or participating in an investigation under this Policy must immediately report such alleged retaliation to the President of the Board of Directors, as appropriate.

Any employee or Board member who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination of employment or removal from the Board of Directors or employment.

VI. CONFIDENTIALITY

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

VII. PERIODIC REVIEWS

This Whistleblower Policy will periodically reviewed (at least once every five years) by the Board, and updates or modifications will be made when needed. The current policy will be posted on NCLT’s website.