GSEM Employee Handbook 2022-2023

WHISTLEBLOWER POLICY Girl Scouts of Eastern Missouri (GSEM) is committed to the highest possible standards of ethical, moral and legal business conduct. In line with this commitment, this policy shall provide an avenue to raise concerns and provide reassurance that those who file a complaint in good faith will be protected from retaliation. A "whistleblower" for the purposes of this policy is a person who, by following the procedures listed below, reports an activity, policy, or practice they have reason to believe is illegal, fraudulent, or unethical. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. Procedures: If a person has knowledge of or a concern about business activity that may be illegal, fraudulent, or unethical, they may file a complaint in a timely fashion and submit the complaint to one of the following GSEM personnel:

1. Immediate manager 2. Next level manager 3. Chief Human Resources Officer 4. Chief Executive Officer 5. Chair, Board of Directors

The person receiving the complaint should immediately inform the Chief Human Resources Officer (CHRO). The CHRO will coordinate a prompt, thorough, and confidential investigation into the allegation. An investigation of unspecified wrongdoing or broad allegations will not be undertaken without verifiable evidentiary support. If any of the personnel listed above are named or involved in the complaint, all of their duties in this policy are assumed by the next listed individual who is not named in or involved in the complaint. When appropriate, the CHRO will periodically provide a status update to the whistleblower, and report progress of the investigation and recommend action to the Chief Executive Officer (CEO). In any case, where the investigation determines there is reasonable cause to believe criminal activity has occurred, the matter will be turned over to the appropriate law enforcement agency. It is preferred that complaints be submitted in writing to ensure a clear understanding of the issues raised; however, they may be made orally and will be documented in writing. All complaints must be factual and should contain as much specific information as possible to allow for proper assessment and investigation. A complaint may be submitted anonymously, but it must provide sufficient corroborating evidence to justify the commencement of an investigation. Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates an illegal, fraudulent, or unethical business activity. Intentionally filing a false complaint--either orally or in writing--is improper conduct and subject to disciplinary action up to and including termination. A whistleblower's identity is confidential to the extent possible within the legitimate needs of the law, the organization, and the investigation. No one shall suffer harassment, retaliation, or adverse employment consequence as a result of a complaint made in good faith or participation in an investigation. Retaliation against a whistleblower or investigation participant is grounds for disciplinary action up to and including termination. Any whistleblower or investigation participant who believes they are being retaliated against should immediately contact the CHRO or CEO. The rights of a whistleblower against retaliation do not include immunity for any personal wrongdoing.

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