United Way of Greater Portland (UWGP) is committed to conducting itself with the highest ethical standards and processes. This whistleblower policy provides a mechanism for all directors, officers, employees, and volunteers to raise good-faith concerns regarding violations of laws or policies without fear of retaliation. Such concerns include, but are not limited to:
Reporting suspected violations of law on the part of UWGP or UWGP employees, including but not limited to federal, state, and local laws and regulations;
Providing truthful information in connection with an inquiry or investigation by a court, agency, law enforcement, or other governmental body;
Reporting a condition or practice relating to UWGP that would put at risk the health or safety of any individual; and
Identifying potential violations of UWGP policy, specifically the policies contained in UWGP’s employee handbook, bylaws or other policy guidelines that should be shared with a person in a leadership capacity.
Failure of a UWGP employee to report a violation of UWGP policies or perceived violations of the law can result in disciplinary action up to and including termination.
It is everyone’s responsibility to raise any concerns or issues that might impact the culture of community and integrity at UWGP. This includes reporting the violation or perceived a violation of any UWGP policies or state or federal law and/or any form of retaliation.
Examples of actions or behaviors that must be reported include but are not limited to:
Provision of false or misleading information on UWGP’s financial documents, grant reports, tax returns, or other public documents;
Provision of false information to or withholding material information from UWGP’s auditors, accountants, lawyers, directors, or other representatives responsible for ensuring UWGP compliance with fiscal and legal responsibilities;
Embezzlement, private benefit, or misappropriation of funds;
Material violation of UWGP policy, including among others, confidentiality, conflict of interest, whistleblower, ethics, and document retention;
Discrimination in violation applicable federal, state and local laws and ordinances;
Retaliation on the basis of previously reported behavior;
Facilitation of or concealing any of the above, or similar actions.
1. Any director, officer, employee, or volunteer (any of these, a “Reporting Individual”) who witnesses a real or a perceived violation of the law or of a UWGP policy shall report the suspected violation to the Treasurer of the Board of Trustees (identified above) or to the leadership of Human Resources (as previously identified)
2. If for some reason the Reporting Individual is uncomfortable with reporting the perceived violation to the Treasurer of the Board of Trustees or to the leadership of Human Resources because the allegation involves both individuals, or for any other reason, he or she shall communicate the concern, confidentially to:
a UWGP Senior Vice President (SVP), or
UWGP’s anonymous hotline at (844) 3-TIPLINE/(844) 384-7546 or http://fiduciasolutions.org/tipline (Organization code: 837554)
3. UWGP will promptly review and investigate complaints. This investigation may include the review of applicable documents and the interview of individuals with information related to the complaint. The individual conducting the investigation will use his/her discretion in determining how best to conduct the investigation.
4. After the investigation has concluded, the investigator will inform the reporting party of the general results of the investigation.
Any Reporting Individual 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 the leadership of Human Resources.
If this option is not appropriate, the individual may report the incident to UWGP’s CEO, SVP, or an officer of the Board of Directors.
Supervisors, managers, and the leadership of Human Resources must immediately inform the CEO or a Board Officer regarding any complaints of retaliation.
A Reporting Individual may also file a complaint with the Maine Human Rights Commission, at 51 State House Station, Augusta, ME 04333 (207-624-6050).
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.