Whistleblower Policy

ADOPTED by the Board of Directors on October 7, 2026. Published through /transparency. Next review: October 2027. Counsel review is recommended. (IRS Form 990, Part VI, Line 13 asks whether the Fund has a written whistleblower policy.)

Adopted by the Board on: October 7, 2026 Next review: October 2027

1. Purpose

The Fund requires its directors, officers, employees, and volunteers to observe high standards of business and personal ethics in the conduct of their duties. This policy establishes a protected channel for reporting suspected wrongdoing and prohibits retaliation against anyone who reports in good faith.

2. What to report

Reportable concerns include, but are not limited to:

• suspected fraud, theft, or misuse of Fund assets;
• accounting or auditing irregularities;
• violations of law, regulation, or Fund policy;
• retaliation for making a report under this policy.

This policy is not a substitute for normal supervisory channels for employment grievances unrelated to wrongdoing.

3. How to report

• Reports may be made in writing or orally to the Executive Director, serving as Compliance Officer. If the concern implicates the Executive Director, the report goes to the Chair of the Board.
• Reports may be made anonymously. Anonymous reporters should understand that anonymity can limit the Fund’s ability to investigate.
• Reports should include as much factual detail as available: what happened, when, who was involved, and any supporting documents.

4. Confidentiality

Reports are treated as confidential to the extent possible consistent with a fair and thorough investigation. The identity of a reporter who does not wish to be identified is protected unless disclosure is required by law or is necessary to the investigation, in which case the reporter is told first where practicable.

5. No retaliation

The Fund prohibits retaliation against any person who in good faith reports a concern, cooperates with an investigation, or refuses to carry out an instruction they reasonably believe would violate the law. Retaliation is itself a violation of this policy and may result in discipline, up to and including removal or termination. Anyone who believes they have been retaliated against should report it under Section 3.

6. Investigation

• The Compliance Officer (or the Board Chair, where the report implicates the Executive Director) assesses each report promptly and determines the appropriate investigation, which may involve outside counsel or auditors for serious matters.
• Investigations are documented. Findings and corrective actions are reported to the Board, with the reporter’s confidentiality preserved as described in Section 4.
• Reports, investigation records, and outcomes are retained under the Fund’s document retention policy.

7. Review

The Board reviews this policy at least annually and after any incident that tests it.