Policy
Whistleblower Policy
Outright International ("Outright") requires its Board of Directors, officers and employees and retained service providers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As representatives of Outright, representatives of Outright must practice honesty and integrity in fulfilling their responsibilities and must comply with all applicable laws and regulations.
The objectives of the Outright Whistleblower Policy are to establish policies and procedures for:
- The submission of concerns regarding questionable accounting or audit matters by employees, directors, officers, partners, vendors, and other stakeholders of the organization, on a confidential and anonymous basis.
- The receipt, retention, and treatment of complaints received by the organization regarding accounting, internal controls or auditing matters.
- The protection of directors, volunteers, employees, and other individuals reporting concerns in good faith from retaliatory actions.
Reporting Responsibility
It is the responsibility of all directors, employees, and other stakeholders who become aware of ethics violations or suspected violations to report them in accordance with this Whistleblower Policy.
Reporting Violations
Individuals with concerns, questions, or complaints are encouraged to contact Outright's Compliance Officer, Head of Operations and CFO directly at [email protected]. Employees may also raise concerns with their direct supervisor or a member of management they are comfortable approaching, who are required to report suspected ethics violations to the Compliance Officer. For suspected fraud, or when an individual is not comfortable raising a concern through internal channels, contacting the Compliance Officer directly is encouraged.
Compliance Officer
Outright's Compliance Officer, who is the chair of the Audit Committee of the Board of Directors, is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at their discretion, shall advise the Executive Director and/or the Audit Committee. The Compliance Officer has direct access to the Board of Directors and is required to report to the Audit Committee at least annually on compliance activity.
Accounting And Auditing Matters
The Audit Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Audit Committee of any such complaint and work with the Committee until the matter is resolved.
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 allegations, which prove to have been made maliciously or knowingly to be false, will be subject to appropriate action.
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.
Handling Of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five (5) business days. All reports will be promptly investigated and appropriate corrective action will be taken.