WHISTLEBLOWER PROTECTION POLICY

1.0 Scope

Fora requires directors, officers, key persons, employees, independent contractors and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As representatives of Fora we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

2.0 Purpose

This Policy is intended to encourage and enable employees and others to raise serious concerns internally so that FORA can address and correct inappropriate conduct and actions. It is the responsibility of board members, key persons, officers, employees and volunteers to report concerns about violations of FORA’s Compliance Guidelines, policies and procedures or suspected violations of laws or regulations that govern Fora’s operations.

3.0 Policy

No Retaliation

A board member, officer, key person, employee, independent contractor or volunteer who in good faith reports an action or suspected action taken by or within the organization that is illegal, fraudulent or in violation of any adopted policy of Fora shall not be discriminated, intimidated, harassed or retaliated against. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline, up to and including termination of employment.

Reporting Procedure

Fora encourages employees to report suspected violations addressed in this policy, and to share their questions, concerns, suggestions or complaints with their supervisor or anyone with whom he or she feels comfortable speaking, including but not limited to, the Compliance Representative or the Human Resources Representative. The organization also has a confidential hotline. The number for the confidential Compliance Hotline can be found in the Fora Employee Handbook and is posted on Fora ADP Portal under Company Announcements.

Compliance Representative

Fora’s Compliance Representative is responsible for ensuring that all complaints about suspected improper conduct are investigated and resolved. The Compliance Representative will advise the Board of Trustees of all complaints and their resolution. No person who is the subject of a whistleblower complaint shall participate in the investigation, review or resolution of such complaint; provided, however, that the Compliance Representative may request that such a person present information as background or answer questions regarding the complaint.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an appropriate investigation.

New York Labor Law Section 740

Fora also complies with the requirements of New York Labor Law section 740. A Notice of Employee Rights, Protections, and Obligations Under Labor Law Section 740 concerning prohibited retaliatory personnel action by employers is posted at employee location and on ADP Portal under Resources.

Fora complies with the requirements of the U.S. AbilityOne Commission Policy 51.406, Rights of Participating Employees (See Addendum). Fora may not interfere with or discourage employees from filing complaints with Central Nonprofit Agencies (CNAs), the Commission, or other appropriate external agencies. Employees have the right to report concerns if they believe Fora has failed to provide the same legal protections, apply the same legal standards, or grant equal access to employment benefits as those provided to non-disabled employees performing comparable work.

Distribution

A copy of this Policy will be distributed to all directors, officers, key persons, employees and to volunteers who provide substantial services to the organization. The Policy is also available on ADP Portal under Resources.

Addendum to Whistleblower Protection Policy

Compliance with AbilityOne Policy 51.406

  1. Purpose

This addendum ensures Fora follows U.S. AbilityOne Policy 51.406, which protects the rights of employees who are blind or have significant disabilities working on AbilityOne contracts. It adds to our existing Whistleblower Protection Policy without changing it.

2. Who This Applies To

This policy covers:

  • All “Participating Employees” (those who are blind or significantly disabled and work under AbilityOne contracts)
  • Staff who supervise, support, or work with these employees (managers, HR, compliance staff, etc.)

3. Employee Rights

Under AbilityOne Policy 51.406, Participating Employees:

  • Must receive the same legal protections and benefits as other employees doing similar work
  • Are covered by all labor laws, including:
  • Anti-discrimination laws
  • Health and safety rules
  • Workers’ compensation and unemployment insurance
  • Must have equal access to:
  • Health insurance
  • Retirement plans
  • Paid time off

Fora cannot prevent or discourage employees from filing complaints with:

  • SourceAmerica (CNA)
  • The U.S. AbilityOne Commission
  • Government agencies (local, state, or federal)

4. How to Report a Complaint

Participating Employees can report concerns through:

  • Fora’s Compliance Hotline
  • Directly to Fora leadership, SourceAmerica, the AbilityOne Commission, or external agencies

5. Protection from Retaliation

Participating Employees are protected from any retaliation (such as discrimination or harassment) for reporting issues in good faith.