Dzokden is committed to fostering a harmonious, enriching, and safe environment for all individuals involved in its charitable, educational, and religious activities, as outlined in our “Dzokden Code of Conduct”. This commitment extends to all staff, board members, officers, leaders, consultants, and volunteers of Dzokden (collectively, “Personnel”). Dzokden expects such Personnel to uphold the highest standards of personal and professional conduct, ensuring integrity and compliance with all relevant laws and regulations in the performance of their duties.

1 – Introduction and Purpose

This Dzokden Whistleblower Protection Policy (“Policy”) is designed to encourage and support Personnel to report any suspected (a) fraudulent or dishonest use or misuse of Dzokden’s resources, or (b) violation of any adopted Dzokden policy (e.g. the Dzokden Code of Conduct) by Personnel, pursuant to the procedures below.

This Policy applies to any matter which is related to Dzokden and does not relate to private acts of an individual not connected to Dzokden. This Policy is intended to supplement but not replace any applicable state and federal laws governing whistleblowing applicable to nonprofit, charitable, and religious organizations.

2 – Violations; Reporting in Good Faith

Personnel are encouraged to report activities that they, in good faith, believe to be fraudulent or dishonest conduct or violation of Dzokden corporate policies (i.e., act as a “whistleblower”), some examples of which include, but are not limited to, the following:

• forgery or alteration of documents or materials;
• unauthorized alteration or manipulation of computer or physical files;
• fraudulent financial reporting;
• pursuit of a benefit or advantage in violation of Dzokden’s Conflict of Interest Policy;
• misappropriation or misuse of Dzokden’s resources, such as funds, educational materials; supplies, or other assets;
• authorizing or receiving compensation for goods not received or services not performed; and
• authorizing or receiving compensation for hours not worked.

3 – Protection from Retaliation

It is contrary to the values of Dzokden to retaliate against any individual who raises concerns in good faith within Dzoken.

Any individual within Dzokden who retaliates against (a) a whistleblower, or (b) an individual who has cooperated in the investigation of suspected fraudulent or dishonest conduct or violation of Dzokden corporate policies is subject to discipline, including but not limited to, termination of employment, role, officer or leader position, or volunteer status.

If an individual believes that someone who reported suspected fraudulent or dishonest conduct or violation of Dzokden corporate policies or who cooperated in the investigation of such is suffering from intimidation, harassment, discrimination, retaliation, or other adverse employment related or volunteer related consequences, the individual should contact the Compliance Officer, or the individual appointed to such comparable role by Dzokden. Any individual who reasonably believes he or she has been retaliated against in violation of this Policy shall follow the same procedures for a whistleblower outlined in Article 4 below.

4 – Reporting Process

A whistleblower should report suspected fraudulent or dishonest conduct or violation of Dzokden corporate policies to their leader or supervisor or, if suspected by a volunteer, to the staff member supporting that volunteer’s work using the Whistleblower Reporting Form attached hereto as Appendix A (the “Form”). If for any reason, the whistleblower finds it difficult to report their concerns to a leader or supervisor or staff member supporting the volunteer’s work, the whistleblower may report concerns using the Form directly to the Compliance Officer (compliance[at]dzokden.org). Leaders (and staff members supervising a volunteer’s work) are required to forward any concerns, including the Forms, to the Compliance Officer in writing, who is responsible for investigating all complaints. In cases where any individual prefers, they may also directly file the Form with the Dzokden President or Spiritual Leader, who will then discuss matters with the Compliance Officer.

Whistleblowers must be cautious to avoid baseless allegations, which are defined as allegations made with reckless disregard for their truth or falsity. Personnel making such allegations may be subject to disciplinary action by Dzokden, and/or legal claims by individuals accused of suspected fraudulent or dishonest conduct or violation of Dzokden corporate policies.

5 – Confidentiality

Dzokden encourages Personnel that report suspected fraudulent or dishonest conduct or violation of Dzokden corporate policies to identify themself when making a report in order to facilitate the ensuing investigation. However, Forms may be submitted anonymously by [insert procedure for reporting anonymously, e.g., filling out a Form and depositing the Form in a designated drop box]. While Dzokden will strive to maintain confidentiality, it is necessary to disclose certain information to conduct a thorough investigation. All individuals involved in investigating or handling complaints will respect the confidentiality of the process to the greatest extent possible, to comply with all applicable laws, and to cooperate with law enforcement authorities.

6 – Role of the Compliance Officer; Handling Reported Violations

The Compliance Officer may be a board member, an officer, or an external party designated to handle complaints. This individual will promptly acknowledge the complaint and initiate an investigation.

Compliance Officer: [Scott Grimes]

All relevant matters, including suspected but unproved matters, will be reviewed and analyzed, with documentation of the receipt, retention, investigation, and treatment of the complaint.

An individual subject to a complaint under this Policy shall not be present at or participate in any deliberations or vote on any matter relating to such complaint. However, the Board of Directors may request that the individual present information or answer questions prior to deliberations or vote on the matter.

The Compliance Officer will advise the Dzokden President and Spiritual Leader on the status of any reported allegations, the current status of the investigation, and the outcome or corrective action taken at the conclusion of the investigation.

The President will regularly update Dzokden’s Board of Directors on the status of each complaint and will additionally provide a quarterly report on compliance activity related to accounting or alleged financial improprieties to the Dzokden Treasurer.

Dzokden is committed to ensuring that all concerns are addressed in a fair and timely manner. Investigations may warrant investigation by an independent person, such as auditors and/or attorneys. The whistleblower will be notified about what actions will be taken, to the extent reasonably possible and consistent with any privacy or confidentiality limitations. If no further action or investigation is to follow, an explanation for the decision will be given to the whistleblower.

Reasonable care should be taken in dealing with suspected misconduct or violations to avoid:

• baseless allegations;
• premature notice to persons suspected of misconduct or violations and/or disclosure of suspected misconduct or violations to others not involved with the investigation; and
• violations of a person’s rights under law.

Due to the important yet sensitive nature of the suspected misconduct or violations, effective professional follow-up is critical. Leaders should not in any circumstances perform any investigative or other follow up steps on their own. Accordingly, a leader who becomes aware of suspected misconduct or violations:

• should not contact the person suspected to further investigate the matter or demand restitution; and
• should not discuss the case with attorneys, the media, or any person other than as
  described herein .

7 – Training and Raising Awareness

This Policy shall be distributed to all Personnel who provide substantial services to Dzokden. Distribution for these purposes may include posting this Policy on Dzokden’s website or, for new Personnel, including this Policy as part of their on-boarding process.

Adopted by the Dzokden Board of Directors
at its Meeting on [Month, Year].
* https://dzokden.org/code-of-conduct/​