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

Douglass Community Land Trust (Douglass CLT) requires each officer, director and key employee annually (1) to review Douglass CLT’s Conflict of Interest Policy (the “Policy”); (2) to disclose any possible personal, familial, or business relationship that reasonably could give rise to a conflict of interest or the appearance of a conflict of interest; and (3) to acknowledge by his or her signature that he or she is acting in accordance with the letter and spirit of such Policy. Please respond to the following questions to the best of your knowledge.

(Board, staff, volunteer)
If you are on another nonprofit board, or active member of a nonprofit, please also list here. . If none, write “N/A” PLEASE NOTE IF YOU ARE A MEMBER of another organization that may also be involved in community development in DC. "Company" means a corporation (for profit or nonprofit), partnership, trust, association, joint venture, sole proprietorship, unincorporated organization, or any other form of business entity. List for each 1)Title/Position 2) Company/ Organization 3)Address

CERTIFICATION

By signing this form below, I certify that:

  1. I have received a copy of Douglass CLT’s conflict of interest policy;
  2. I have read and understand the policy;
  3. I am currently and agree to remain in compliance with the policy; and
  4. The information set forth above is true and complete to the best of my knowledge.
Clear Signature

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          

Step 1 of 2

Whistleblower Policy & Acknowledgement

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 Douglass CLT, 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, ensure that Douglass CLT has a governance and accountability structure that supports its mission, and encourage and enable directors, officers, members, employees, and volunteers 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 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. Nothing in this policy provides any individual with additional rights or causes of action not otherwise available under applicable law.

Reporting Responsibility and Terms

All directors, officers, members, employees, and volunteers 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
  • Authorizing or receiving compensation for hours not worked

Whistleblower

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 Douglass CLT that they believe to be fraudulent or dishonest.

Good Faith

Anyone reporting a Violation must act in good faith, without malice to the organization or any individual, and have reasonable grounds for believing that the information shared indicates a Violation has occurred. The reporter does not need to prove a Violation but should not knowingly make malicious or false reports, as doing so is considered 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 cooperates in an investigation shall suffer harassment, retaliation, or adverse employment consequences. Any individual who retaliates against someone who has reported a Violation in good faith or cooperated in an investigation is subject to discipline, including termination.

If you believe that someone who has made a good faith report is suffering harassment, retaliation, or adverse employment consequences, please contact the Compliance Officer.

Reporting Process

All directors, officers, members, employees, and volunteers should address concerns relating to a Violation to someone within the organization who can properly address them. In most cases, an employee or volunteer’s direct supervisor is the best person to address a concern. However, if you are not comfortable reporting to your supervisor or are not satisfied with their response, you may report to another manager or 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 report should be directed to the Compliance Officer. The Executive Director will review the concern with the Compliance Officer.

All reports of suspected Violations must be in writing (including electronic communication) or communicated via phone or personal meeting. Reports should include a full statement of the acts or omissions, relevant dates, and should explicitly state that they are being made pursuant to this policy. Reports should include contact information for the complainant. However, anonymous reports may be submitted, though anonymity could limit the investigation’s effectiveness. The investigating party will make every effort to maintain confidentiality.

Investigative Process

The Executive Director or Compliance Officer will acknowledge receipt of a Violation report within five business days if the sender’s identity is disclosed or a return address is provided.

If the Executive Director is the subject of the reported Violation, the Compliance Officer is responsible for investigating and taking appropriate corrective action.

If the Executive Director is not the subject of the reported Violation, either the Executive Director or Compliance Officer will investigate and take corrective action as needed.

Accounting & Auditing Matters

The audit committee of the board of directors is responsible for addressing all reported concerns related to corporate accounting practices, internal controls, or auditing. The Executive Director or Compliance Officer must immediately notify the audit committee of any such concern.

The Compliance Officer has direct access to the Board of Directors and must report to them at least annually on compliance activity.

The Compliance Officer for 2025 is Julian “Jay” Forth, email julian.n.forth@gmail.com

(Board, staff, volunteer)

CERTIFICATION

My signature below indicates my receipt and understanding of this policy.  I also verify that I have been provided with an opportunity to ask questions about this policy.

Clear Signature