Board members, key volunteers and staff below our two forms you are required to complete each year.
1) Conflict of Interest Certification and Disclosure form
2) Whistleblower Acknowledgment
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General
Douglass Community Land Trust (Douglass CLT) requires directors, officers, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities within the Organization. As representatives of the Organization, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
The purpose of this Whistleblower Policy is to create an ethical and open work environment, to ensure that Douglass CLT has a governance and accountability structure that supports its mission, and to encourage and enable directors, officers, members, employees and volunteers of the Organization to raise serious concerns about the occurrence of illegal or unethical actions within the Organization before turning to outside parties for resolution.
Notwithstanding anything contained in this Whistleblower Policy to the contrary, this Whistleblower Policy is not an employment contract and does not modify the employment relationship between Douglass CLT and any of its directors, officers, members, employees or volunteers, nor does it change the fact that all employees of the Organization are employees at will. Nothing contained in this Whistleblower Policy provides any director, officer, member, employee or volunteer of the Organization with any additional rights or causes of action not otherwise available under applicable law.
Reporting Responsibility and Terms
All directors, officers, members, employees and volunteers of the Organization have a responsibility to report any action or suspected action taken within the Organization that is illegal or unethical (“Violations”).
Violations / Fraudulent or Dishonest Conduct: A deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples of such conduct include, but are not limited to:
- Forgery or alteration of documents;
- Unauthorized alteration or manipulation of computer files;
- Fraudulent financial reporting;
- Pursuit of a benefit or advantage in violation of Douglass CLT’s Conflict of Interest Policy;
- Misappropriation or misuse of Douglass CLT resources, such as funds, supplies or other assets;
- Authorizing or receiving compensation for goods not received or services not performed; and
- Authorizing or receiving compensation for hours not worked
Whistle-Blower: An employee, consultant, member, or volunteer who informs a supervisor, the Chair of the Board, the Compliance Officer, or the Executive Director about an activity relating to the Douglass CLT which that person believes to be fraudulent or dishonest.
Good Faith: Anyone reporting a Violation must act in good faith, without malice to the organization or any individual in the organization and have reasonable grounds for believing that the information shared in the report indicates that a Violation has occurred. A person who makes a report does not have to prove that a Violation has occurred. However, any report which the reporter has made maliciously or any report which the reporter has good reason to believe is false will be viewed as a serious disciplinary offense.
Compliance Officer: The Secretary of the Douglass CLT Board of Directors shall be the designated Whistleblower Compliance Officer.
No Retaliation
No one who in good faith reports a Violation or who, in good faith, cooperates in the investigation of a Violation shall suffer harassment, retaliation or adverse employment consequences. Any individual within the Organization who retaliates against another individual who has reported a Violation in good faith or who, in good faith, has cooperated in the investigation of a Violation is subject to discipline, including termination of employment or volunteer status.
If you believe that an individual who has made a good faith report of a Violation or who has, in good faith, cooperated in the investigation of a Violation is suffering harassment, retaliation or adverse employment consequences, please contact the Compliance Officer.
Reporting Process
All directors, officers, members, employees and volunteers should address their concerns relating to a Violation to any person within the Organization who can properly address those concerns. In most cases, the direct supervisor of an employee or volunteer is the person best suited to address a concern. However, if you are not comfortable filing your complaint with your supervisor or if you are not satisfied with your supervisor’s response, you are encouraged to file your complaint with anyone in management whom you are comfortable approaching, or directly with the Compliance Officer. All staff are required to report suspected Violations to the Executive Director unless the Executive Director is the subject of the complaint, in which case the suspected Violation should be reported to the Compliance Officer. Upon receiving a reported Violation, the Executive Director will review the concern with the Compliance Officer.
All reports of suspected Violations must be in writing (may include electronic communication), or phone or personal meeting. All reports must include a full statement of the acts or omissions, along with the relevant dates, forming the basis of the complaint. In addition, the complaint should state that it is being made pursuant to this policy. In order to facilitate the investigation, the complaint should include contact information for the complainant. However, an individual submitting a complaint on a confidential, anonymous basis may, but is not required to, include contact information. It should be noted that an investigation into a complaint submitted by an individual on a confidential, anonymous basis could potentially result in identification of the individual. In such a case, the investigating party will use its best efforts to maintain the confidentiality and anonymity of the complaint and complainant.
Investigative Process
The Executive Director or Compliance Officer will notify the sender and acknowledge receipt of a report of Violation within five business days, but only to the extent the sender’s identity is disclosed or a return address is provided.
In instances where the Executive Director is the subject of the reported Violation, the Compliance Officer is responsible for promptly investigating the report and for causing appropriate corrective action to be taken if warranted by the investigation. In instances where the Executive Director is not the subject of the reported Violation, the Executive Director or the Compliance Officer is responsible for promptly investigating the report and for causing appropriate corrective action to be taken if warranted by the investigation.
Accounting & Auditing Matters
The audit committee of the board of directors is responsible for addressing all reported concerns or complaints of Violations relating to corporate accounting practices, internal controls or auditing. Therefore, the Executive Director or Compliance Officer must immediately notify the audit committee of any such concern or complaint.
The Compliance Officer has direct access to the Board of Directors and is required to report to the Board of Directors at least annually on compliance activity.
The Compliance Officer for 2025 is Julian “Jay” Forth, email julian.n.forth@gmail.com
Your form entry has been saved and a unique link has been created which you can access to resume this form.
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Please note, this link should not be shared and will expire in 30 days, afterwards your form entry will be deleted.