Ethics Complaint and Whistleblower Policy

CALL FOR DUTY Ethics Complaint and Whistleblower Policy

1. Purpose
Achieving CALL FOR DUTY’ mission of alleviating suffering, poverty, and oppression by helping people build secure, productive and just communities requires all of us to perform with the highest personal and professional ethical conduct. The culture we strive to create at Call for Duty requires caring deeply and recognizing that every voice matters. This policy serves to guide team members who have specific concerns that our common commitments to ethical conduct may be at risk. It addresses how team members can report the specific concerns, the protections against retaliation for reporting, and how CALL FOR DUTY will address reports.

2. Scope of Policy
This policy applies to: CALL FOR DUTY Global and CALL FOR DUTY Europe, their subsidiaries and affiliated organizations (collectively “CALL FOR DUTY”); Members of CALL FOR DUTY’ Boards of Directors, officers, management, Team Members, seconded employees, interns, and volunteers (collectively “Team Members”); and Sub-recipients, partner organizations, contractors, outside experts (including attorneys), consultants, agents, representatives, and any other organization or individual that acts on CALL FOR DUTY’ behalf or at CALL FOR DUTY’ direction (collectively “Partners”).

3. Policy Statements
3.1. CALL FOR DUTY expects all Team Members and Partners to adhere to the highest standards of accountability, which requires honest and ethical conduct. CALL FOR DUTY expects management to maintain a culture that supports and strengthens commitment to these high standards.

3.2. It is the responsibility of all Team Members to comply with CALL FOR DUTY’ ethical principles as contained in the Code of Conduct, Anti-Corruption, Anti-Bribery, Child Safeguarding, and Anti-Trafficking Policies (“Code of Conduct Policies”) and to report immediately Violations or suspected Violations in accordance with this policy.

3.3. This policy is intended to encourage and enable Team Members and Partners to raise allegations of violations of CALL FOR DUTY’ Code of Conduct Policies, waste and/or mismanagement of funds, abuse of authority, substantial and specific danger to public health and safety caused by CALL FOR DUTY or its Partners, or violations of any law, rule, or regulation related to donor requirements, or other illegal conduct (collectively referred to herein as “Violations”) in good faith, without the fear of retaliation, internally so that
CALL FOR DUTY can address and correct inappropriate conduct and actions. It is the responsibility of all Team Members and expectation of all Partners to protect CALL FOR DUTY, its mission and its beneficiaries and donors from Violations and to ensure that Violations are reported and addressed.

3.4. No Team Member or Partner who reports a Violation will suffer harassment, retaliation, or adverse employment consequence, such as being terminated, demoted, or otherwise discriminated against as a reprisal for reporting a Violation. This whistleblower protection cannot be waived by any agreement, policy, form, or condition of employment.

3.5. CALL FOR DUTY will not tolerate retaliation and a Team Member who is determined to have retaliated against someone for reporting a Violation may be subject to discipline up to and including termination of employment.
3.6. Reports of retaliation should be made to the CALL FOR DUTY. Reports of retaliation will be investigated promptly in a manner intended to protect confidentiality as much as practicable, consistent with a full and fair investigation.

3.7. This policy and CALL FOR DUTY’ hotline are not intended to address general complaints about the workplace, interpersonal issues, or other issues not related to Violations as described above. General complaints should be raised with supervisors or other responsible functions within CALL FOR DUTY.

3.8. Knowingly making a false allegation or making false or misleading statements in an allegation or to CALL FOR DUTY investigators, external law enforcement, or donor investigators may also lead to disciplinary action up to and including termination of employment.

3.9. CALL FOR DUTY will not require its Team Members or Partners to sign or comply with internal confidentiality agreements or statements that prohibit or otherwise restrict Team Members or Partners from lawfully reporting waste, fraud, or abuse to a designated investigative or law enforcement representative of a department or agency authorized to receive such information.

3.10. CALL FOR DUTY and its donors greatly appreciate Violations first being reported internally as described in this Policy. Internal reporting ensures CALL FOR DUTY can fully follow-up, including proper reporting to the donor as and when the donor requires. The whistleblower protections in this policy apply to Team Members and Partners who report Violations, weather reports are made internally to CALL FOR DUTY or directly to authorities or institutional donors.

4. Processes and Procedures Required to Ensure Compliance with this Policy

4.1. Education and Awareness

4.1.1. All Team Members will be trained on the contents of this policy via CALL FOR DUTY’ mandatory Code of Conduct training.

4.1.2. All CALL FOR DUTY offices will display the CALL FOR DUTY Whistleblower Policy posters, translated into the primary language of the office, in conspicuous locations where all staff will see them.

4.2. Partner Contractual Requirements

4.2.1. All CALL FOR DUTY agreements with Partners will include a clause that requires the Partner to adhere to the substance of this policy and to communicate this policy to their staff.

4.3. Reporting Procedures

4.3.1. CALL FOR DUTY suggests that Team Members share their questions, concerns, suggestions or complaints with their supervisor or their senior leadership. If Team Members concerned about a potential Violation of CALL FOR DUTY’ Code of Conduct Policies are not comfortable speaking with supervisors or senior leadership are concerned there may be a conflict of interest, or are not satisfied with their supervisor’s or senior leadership’s response, they are encouraged to speak with an Ethics Officer through CALL FOR DUTY’

Where reported Violations may affect an individual’s physical or emotional safety or well-being, CALL FOR DUTY will seek to provide timely referrals for medical and/or psychosocial support. CALL FOR DUTY will also seek to ensure the safety and security of the individual at risk as well as the safety of any other Team Members, Partners, and communities that could be at risk.

4.3.2. Supervisors and/or Team Leaders are required to immediately report all complaints about Violations of CALL FOR DUTY’ Code of Conduct Policies, preferably in writing, to the Ethics Team.

4.3.3. Reporting to the hotline may be done anonymously, although this may impede the ability of the Ethics Team to assess the complaint or conduct its investigation. CALL FOR DUTY encourages non-anonymous reporting.

4.3.4. In the event that a team member wishes to report an allegation against a CALL FOR DUTY executive team member, the allegation may be made either to the Ethics Team or directly to CALL FOR DUTY’ Joint Audit and Risk Committee Chair. Nothing herein should be interpreted as a limitation on CALL FOR DUTY’ Joint Audit and Risk Committee’s ability to investigate an allegation as it sees fit.

4.4. Follow-Up and Investigation of Complaints

4.4.1. The Ethics Team is responsible for ensuring that all complaints are quickly assessed for credibility and determining whether the complaint merits further investigation. The Ethics Team will follow up on complaints promptly. Notice will be sent to the person who submitted the complaint to acknowledge receipt of the reported Violation or suspected Violation.

4.4.2. The Ethics Team will ensure a full and complete investigation of complaints deemed to merit further investigation. The Ethics Team will use the most efficient means and methodology of timely determining the full facts and scope of any wrongdoing while ensuring the integrity and independence of the investigation. CALL FOR DUTY will also seek to address safety and security concerns related to any investigation and will seek to ensure the well-being of any victim of wrong-doing as part of its investigation. The investigation methodology and the actual investigative team members will vary based on the nature and scope of the alleged Violation. The Ethics Team may rely on other CALL FOR DUTY team members to participate in or conduct the investigation, may conduct the investigation themselves, may hire external, specially trained investigators to participate in or conduct the investigation, or may rely on external law enforcement to conduct the investigation.

4.4.3. In the event, a report is determined non-credible (or does not allege a Violation of CALL FOR DUTY’ Code of Conduct Policies or other illegal or unethical conduct) and will not be investigated, the Ethics Team will ensure that such determination is made in writing with justification for that determination. The Ethics Team will ensure that all investigations are fully documented in a full and final report detailing the investigative means and methodology, evidence, factual conclusions, and corrective measures.

4.4.4. When conducting its investigations, CALL FOR DUTY will strive to keep the investigation and the identity of the reporting individual as confidential as possible. The identity of the reporting individual will only be disclosed after first and foremost considering the safety and security of the reporting individual and only when necessary to ensure a full and complete investigation, to ensure lessons are learned and corrective measures are instated after the investigation, or when required or requested by external donors or law enforcement in order to facilitate their investigation.

5. Oversight

5.1. Country Directors are ultimately responsible for ensuring that all complaints in their country are properly reported to the Ethics Team and that whistleblowers in their country are not retaliated against.

5.2. CALL FOR DUTY’ General Counsel is responsible for overseeing the Ethics Team and its decisions under this policy.

5.3. Assessments and investigation reports are reviewed by the Ethics Incident Review Committee (IIRC), which is chaired by the Ethics Team and currently comprised of General Counsel, Directors of International Finance, Finance & Compliance Support Unit, Compliance, MCE Governance & Risk, MCE Finance, Internal Audit, Global HRS, and Global Field Programming. In the event that the integrity or independence of the investigation merits it, the Ethics Team may require individual EIRC members to recuse themselves from reviewing a particular matter or may constitute a special EIRC comprised of different individuals for a particular matter. In the event the complaint involves a senior leader, the General Counsel may work directly with the Joint Audit and Risk Committee to review the matter. No matter may be closed until the EIRC unanimously determines the issue can be closed.

5.4. The Ethics Team provides a report of incidents to the Joint Audit and Risk Committee at each of its regularly scheduled meetings. The Joint Audit and Risk Committee has ultimate oversight of complaints and their resolution.

6. Policy Administration
Responsibility for ensuring this policy is monitored, enforced, and remains up-to-date and compliant rests with CALL FOR DUTY’ Legal Department and General Counsel.

7. Approved Policy
This policy was approved by the CALL FOR DUTY Board of Directors on March 7, 2018, and CALL FOR DUTY Europe Board of Directors on March 1, 2018. This policy may only be amended or changed with the approval of the Board(s).

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