It is the responsibility of all directors, officers, employees, volunteers and contractors of Prison Journalism Project to report in good faith any conduct by a Prison Journalism Project director, officer, employee, volunteer or contractor that the reporting individual reasonably believes is or may be illegal, fraudulent, a substantial and specific danger to public health or safety or in violation of any adopted policy of Prison Journalism Project (collectively, “Concerns”).
REPORTING RESPONSIBILITY
All Concerns should be reported as soon as practicable. Any individual who seeks to report a Concern should bring it to the attention of the individual’s supervisor or, if the conduct in question involves the supervisor, the Chief Operating Officer or the Chief Executive Officer or, if it involves either of those, the Chair of the Board of Directors. Concerns reported under this policy may be in writing (including by email) or by phone, and the reporting may be anonymous.
Individuals who report Concerns must exercise sound judgment and reasonably believe in good faith that the information disclosed indicates conduct that is or may be illegal, fraudulent, a substantial and specific danger to public health or safety, or in violation of any adopted policy of Prison Journalism Project. An employee who intentionally files a false report may be subject to discipline, up to and including discharge.
INVESTIGATIONS
Prison Journalism Project shall promptly investigate all reported Concerns and will take appropriate corrective action, if warranted. This investigation shall be coordinated by the Chief Operating Officer. However, if the investigation relates to the Chief Operating Officer’s conduct, the investigation shall be coordinated by the most senior officer of Prison Journalism Project whose conduct is not the subject of the individual’s report, or a person designated by such officer.
An employee who is also a member of the Board of Directors may not take part in any Board deliberations concerning the administration of this Whistleblower Policy. In addition, any individual who is the subject of a whistleblower complaint may not be present at or participate in any Board deliberations or voting on the matter relating to the complaint. Nothing in this policy shall prohibit the Board of Directors from requesting that the individual who is the subject of the complaint present background information or answer questions prior to the commencement of deliberations or voting.
NO RETALIATION
Prison Journalism Project will not take any retaliatory action against any individual, including a former employee or independent contractor, who in good faith reports a Concern, provides information or participates in an internal or government investigation of any such Concern, or objects to or refuses to participate in any activity, policy or practice giving rise to such Concern. Acts of retaliation should be reported immediately to the Chief Operating Officer or the Chief Executive Officer. Any employee who retaliates against an individual who has reported a Concern in good faith may be subject to discipline, up to and including discharge.
Retaliatory action includes but is not limited to (i) discharge, suspension or demotion or other adverse employment action taken against an employee in the terms and conditions of employment, as well as the threat of any such adverse employment action, (ii) any actions that would adversely impact the reporting individual’s current or future employment or (iii) contacting immigration authorities or reporting the immigration status of such individual or their family members, or threatening to do so.
The right to be free of retaliation does not preclude Prison Journalism Project from taking action against the employee relating to the employee’s job performance or other conduct, and does not preclude other action regarding directors, officers, volunteers or contractors that are otherwise consistent with law and with the Fund’s bylaws and policies.
CONFIDENTIALITY
Insofar as is reasonably practicable, Prison Journalism Project will maintain the confidentiality of any individual reporting a Concern, although the individual’s identity may have to be disclosed to conduct the appropriate investigation, to comply with the law or legal process, or to provide a person accused with the opportunity to defend themselves against the accusation.
DISTRIBUTION
This policy shall be distributed to all directors, officers, employees and contractors of Prison Journalism Project, and to volunteers who provide substantial services to Prison Journalism Project. This Policy shall be posted on Prison Journalism Project’s website.
QUESTIONS
Anyone who has questions regarding this policy should contact the Chief Operating Officer, who shall be the administrator of the policy.