Nonprofit Whistleblower Policy Compliance and Implementation Review
Whistleblower protection policies are required for nonprofits under Sarbanes-Oxley criminal provisions and are specifically asked about on IRS Form 990 Part VI. Effective whistleblower policies protect the organization from fraud, regulatory violations, and the reputational and financial harm they cause.
- Industry: Nonprofit
- Frequency: Annually
- Estimated Time: 1-2 hours
- Role: Board Secretary / Executive Director
- Total Items: 28
Policy Existence and Board Adoption
Verify policy exists and is board-adopted.
- Written whistleblower protection policy formally adopted by the board?
- Board minutes reflect adoption and periodic review of policy?
- Policy is dated and version-controlled?
- Policy reviewed by legal counsel for compliance with applicable law?
Required Policy Provisions
Verify policy contains required provisions.
- Policy covers all employees, volunteers, board members, and contractors?
- Protected activities clearly defined (reporting financial irregularities, legal violations, safety concerns)?
- Non-retaliation provision prohibiting adverse action against good-faith reporters?
- Confidentiality protections for whistleblowers included?
- Policy addresses consequences of knowingly false reports?
Reporting Mechanisms
Verify reporting mechanisms are adequate.
- Multiple reporting channels available (supervisor, board chair, anonymous hotline)?
- Anonymous reporting mechanism available?
- Direct access to board chair or audit committee for serious concerns?
- External or independent reporting option available (ethics hotline)?
- Reporting mechanisms communicated to all covered persons?
Complaint Handling Procedures
Verify complaint handling procedures are adequate.
- Documented complaint investigation procedure in place?
- Designated person or committee responsible for investigating complaints?
- Investigation timeline and escalation process defined?
- Process for informing reporter of outcome (within confidentiality limits)?
- Investigation documentation requirements and retention defined?
Training and Distribution
Verify policy is communicated and training provided.
- Policy distributed to all employees, board members, and key volunteers?
- New hire orientation includes whistleblower policy training?
- Annual reminder of policy distributed to all covered persons?
- Board members trained on whistleblower policy and their obligations?
Monitoring and Compliance
Verify compliance monitoring is in place.
- All complaints logged and tracked to resolution?
- Monitoring in place to detect potential retaliation against reporters?
- Board receives periodic reports on complaints received and resolved?
- Documentation ready to answer Form 990 Part VI Line 13 affirmatively?
- Policy effectiveness assessed through staff surveys or feedback?
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Why Use This Nonprofit Whistleblower Policy Compliance and Implementation Review?
This nonprofit whistleblower policy compliance and implementation review helps nonprofit teams maintain compliance and operational excellence. Designed for board secretary / executive director professionals, this checklist covers 28 critical inspection points across 6 sections. Recommended frequency: annually.
Frequently Asked Questions
What does the Nonprofit Whistleblower Policy Compliance and Implementation Review cover?
This checklist covers 28 inspection items across 6 sections: Policy Existence and Board Adoption, Required Policy Provisions, Reporting Mechanisms, Complaint Handling Procedures, Training and Distribution, Monitoring and Compliance. It is designed for nonprofit operations and compliance.
How often should this checklist be completed?
This checklist should be completed annually. Each completion takes approximately 1-2 hours.
Who should use this Nonprofit Whistleblower Policy Compliance and Implementation Review?
This checklist is designed for Board Secretary / Executive Director professionals in the nonprofit industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.
Can I download this checklist as a PDF?
Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.