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Nonprofit Whistleblower Policy | Freed Maxick Nonprofit Consulting

Written by Holly Hejmowski, CPA | Feb 26, 2025 3:02:58 PM

Protecting employees protects the organization

A whistleblowing policy is a formal set of guidelines that allows employees, volunteers, board members, vendors, and other stakeholders to report unethical, illegal, or improper activities within an organization without fear of retaliation. It establishes a clear process for reporting concerns, ensuring that issues like fraud, financial mismanagement, discrimination, or safety violations are addressed properly.

Even for a not-for-profit (NFP) organization, a well-structured whistleblower policy is a key component of good governance, ensuring that wrongdoing is addressed while protecting those who come forward. Perhaps most important, a policy shields individuals from retaliation, fostering a culture where people feel safe reporting concerns and strengthens organizational reputation by demonstrating a commitment to ethical operations, which is essential for donors, stakeholders, and the public.

 

Nonprofit Whistleblower Policy: A necessary tool

A not-for-profit organization— to maintain ethical integrity, transparency, and trust among stakeholders— must demonstrate that it is taking proactive measures that safeguard its mission, resources, and reputation. A well-structured whistleblower policy protects integrity and reputation.

Consider that an NFP relies on public trust. A sound policy encourages employees, volunteers, and stakeholders to report misconduct, ensuring ethical operations. With a clear reporting structure, it encourages accountability and helps detect and prevent fraud, financial mismanagement, or other unethical behavior. Many NFPs must adhere to governance best practices or legal requirements. Like with IRS Form 990, which asks if the not-for-profit has a whistleblower policy.


The importance of nonprofit policy making

A policy establishes a clear process for reporting concerns, ensuring that issues like fraud, financial mismanagement, discrimination, or safety violations are addressed properly. It identifies financial irregularities, harassment, or ethical breaches before they escalate. The policy creates stronger governance as it reinforces a culture of transparency and ethical leadership and demonstrates commitment to accountability, encouraging donor and grantor trust. And, it enables employees and volunteers feel empowered to speak up, leading to a more ethical and supportive environment.

In addition to a written, formal policy, organizations should consider tools to support the facilitation of anonymous reporting. Whether implementing a hotline or software, it’s important to consider the features, such as whether or not it can be accessed by all devices, i.e. phone, web, etc., and is secure and encrypted.

 

Protecting nonprofit whistleblowers

The U.S. government has established, strengthened, and enforced laws that provide protections for employees including threat of retaliation. Retaliation against whistleblowers refers to any adverse actions or punitive measures taken by an organization against an individual who has reported misconduct, unethical behavior, or illegal activities. These negative responses can include, but are not limited to:

  • Termination or Demotion: Removing the whistleblower from their position or demoting them as a consequence of their report.
  • Harassment or Intimidation: Subjecting the individual to hostile behavior, threats, or undue pressure intended to silence or discourage future reporting.
  • Exclusion: Isolating or ostracizing the whistleblower from team activities, meetings, or decision-making processes.
  • Career Impediments: Blocking opportunities for promotions, raises, or professional development.

Effective whistleblower protections aim to create a safe environment where individuals can report issues without fear of retribution.

 

Contact Nonprofit Accounting & Consulting Professionals

Freed Maxick’s Not-For-Profit professionals support organizations to safeguard their operations and secure their place in the community. To understand the risks, impacts, and protections of a policy on your organization, schedule a complimentary consultation with Holly Hejmowski, Director of Assurance and Advisory Practice, at Holly.Hejmowski@freedmaxick.com.