SAR History                        Education                        Patriotism                        Genealogy

WHISTLEBLOWER POLICY

 

 
SECTION 1.  GENERAL
 
NSSAR Code of Organization Conduct (hereinafter referred to as the Code) requires officers, trustees, committee chairmen and senior staff to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.  The same high standards are expected of all members, employees and volunteers.  Officers, trustees, committee chairmen, senior staff, committee members, and employees are representatives of NSSAR and must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
 
The objectives of the NSSAR Whistleblower Policy are to establish policies and procedures for:
 
  • The submission of concerns regarding questionable accounting or audit matters by officers, trustees, committee chairmen, committee members, senior staff, employees, and other stakeholders of NSSAR, on a confidential and anonymous basis.
  • The receipt, retention, and treatment of complaints received by NSSAR regarding accounting, internal controls, or auditing matters.
  • The protection of officers, trustees, committee chairmen, committee members, senior staff, employees, and other stakeholders reporting concerns from retaliatory actions.
 
SECTION 2.  REPORTING RESPONSIBILITY
 
Each officer, trustee, committee chairman, committee member, senior staff, employee and other stakeholder of NSSAR has an obligation to report in accordance with this Whistleblower Policy (a) questionable or improper accounting or auditing matters, and (b) violations and suspected violations of NSSAR Organization’s Code (hereinafter collectively referred to as Concerns).
 
SECTION 3.  AUTHORITY OF NSSAR INSPECTOR GENERAL
 
The NSSAR Inspector General is appointed by the President General for a three year term.  The NSSAR Chief Compliance Officer is appointed by the President General and his term will end simultaneously with the term of the President General.  All reported Concerns will be forwarded to the NSSAR Inspector General in accordance with the procedures set forth herein.  The NSSAR Inspector General shall be responsible for investigating, and making appropriate recommendations to the NSSAR Chancellor General and the NSSAR Executive Committee.  If the NSSAR Inspector General is the subject of the Concern, the NSSAR Chief Compliance Officer will receive the reported Concerns, and be responsible for investigating, and making appropriate recommendations to the NSSAR Chancellor General and the NSSAR Executive Committee.
 
SECTION 4.  NO RETALIATION
 
This Whistleblower Policy is intended to encourage and enable officers, trustees, committee chairmen, committee members, senior staff, employees and other stakeholders to raise Concerns within NSSAR for investigation and appropriate action.  With this goal in mind, no officer, trustee, committee chairman, committee member, senior staff, employee or other stakeholder who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences.  Moreover, a NSSAR member or employee who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including referral to the NSSAR Ethics Committee for possible action or termination of employment.
 
SECTION 5.  REPORTING CONCERNS
 
Employees
 
Employees should first discuss their Concern with their immediate supervisor.  If, after speaking with his or her supervisor, the individual continues to have reasonable grounds to believe the Concern is valid, the individual should report the Concern to the Executive Director.  In addition, if the individual is uncomfortable speaking with his or her supervisor, or the supervisor is a subject of the Concern, the individual should report his or her Concern directly to the Executive Director.  
 
If the individual is uncomfortable speaking with his or her supervisor, or the Executive Director, the individual should report his or her Concern directly to the NSSAR Inspector General.
 
If the Concern was reported verbally to the Executive Director, the reporting individual, with assistance from the Executive Director shall reduce the Concern to writing.  The Executive Director is required to promptly report the Concern to the NSSAR Inspector General, who has specific and exclusive responsibility to investigate all Concerns.  If the Executive Director, for any reason, does not promptly forward the Concern to the NSSAR Inspector General, the reporting individual should directly report the Concern to the NSSAR Inspector General.  Contact information for the NSSAR Inspector General may be obtained from the NSSAR website.  Concerns may also be submitted anonymously.  Such anonymous Concerns should be in writing and sent directly to the NSSAR Inspector General.
 
NSSAR Members and Other Stakeholders
 
NSSAR members and other stakeholders should submit Concerns in writing directly to the NSSAR Inspector General.  Contact information for the NSSAR Inspector General may be obtained from the NSSAR website. 
 
NSSAR Web Based Hotline
 
Concerns can be submitted to the NSSAR Inspector General through the Web Based Hotline, which is included on the NSSAR Members Only website.  An online form has been created for reporting Concerns directly to the NSSAR Inspector General.  
 
Acting in Good Faith
 
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the NSSAR Code of Organizational Conduct.  The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including referral to the NSSAR Ethics Committee for possible action or termination of employment.  Such conduct may also give rise to other actions, including civil lawsuits. 
 
SECTION 6.  HANDLING OF REPORTED VIOLATIONS
 
The NSSAR Inspector General shall address all reported Concerns.  The NSSAR Inspector General shall immediately notify the NSSAR Chancellor General and the President General of any such reported Concern.  The NSSAR Inspector General will notify the sender and acknowledge receipt of the Concern within seven business days, if possible.  It will not be possible to acknowledge receipt of anonymously submitted Concerns.
 
The NSSAR Inspector General will promptly investigate all reports, and appropriate corrective action will be recommended to the NSSAR Chancellor General and the Executive Committee, if warranted by the investigation.  In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the Concern.
 
The NSSAR Inspector General, with the concurrence of the Executive Committee, has the authority to obtain resources deemed necessary to conduct a full and complete investigation of the allegations.
 
SECTION 7.  CONFIDENTIALITY
 
Reports of Concerns and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
 
Disclosure of reports of Concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including referral to the NSSAR Ethics Committee for possible action or termination of employment.  Such conduct may also give rise to other action, including civil lawsuits.