STF requires its directors, employees, and contractors to observe high standards of business and personal ethics when conducting their duties and responsibilities. In accordance with this whistleblower policy, it is the responsibility of all directors, employees, and contractors to report any activities or practices that may be illegal, could result in harm to STF or its projects, or may be contrary to STF’s policies, including violations related to:
• Accounting controls and procedures
• Child protection
• Confidential or proprietary information
• Conflicts of interest
• Equal employment opportunity
• Fraud
• Harassment
• Legal compliance
No Retaliation
No employee or contractor who, in good faith, reports a violation shall suffer harassment, retaliation, or adverse employment consequences. An employee or contractor who retaliates against someone who has reported a violation in good faith is subject to disciplinary action, up to and including termination. This policy is intended to encourage and enable stakeholders to promptly raise serious concerns to STF.
Reporting Violations
All leaders and directors within STF encourage employees or contractors to share their questions, concerns, suggestions, or complaints. In most cases, the project director is in the best position to address and area of concern for an employee or contractor. However, if an employee or contractor is not comfortable speaking with the project director or is not satisfied with the project director’s response, the employee or contractor is encouraged to speak with the director of human resources, an account manager, or anyone in a management position with whom they are comfortable approaching. All managers are required to report suspected violations to STF’s general counsel, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when an employee or contractor is not satisfied or is uncomfortable with following STF’s open door policy, individuals should contact STF’s general counsel directly.
For violations related to harassment or child protection, please also refer to the specific sections of this handbook related to harassment and child protection for additional guidance.
General Counsel
STF’s general counsel, or such other disinterested individual as is appointed by the general counsel, is responsible for investigating and resolving all reported complaints and allegations violations and, at their discretion, shall so advise STF’s board of directors. All claims should be directed to generalcounsel@sixteenthirtyfund.org.
Accounting and Auditing Matters
The board of directors shall address all reported concerns or complaints regarding STF’s accounting practices, internal controls or auditing. The general counsel shall immediately notify the president and board of directors of any such complaint and work with the appropriate parties until the matter is resolved.
Acting in Good Faith
Anyone who files a complaint concerning a violation or suspected violation must act in good faith, having reasonable grounds for believing the information disclosed indicates a violation.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complaint or may be submitted anonymously directly to:
General Counsel
Sixteen Thirty Fund
1828 L Street, NW
Suite 300-B
Washington, DC 20036
Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations
The general counsel will acknowledge receipt of the reported violations or suspected violation within five business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.
