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Whistleblower Protection Policy
01. Introduction

Village Hope International (VHI) is committed to upholding the highest standards of ethical conduct, transparency, and accountability in all aspects of its work. As a U.S.-based 501(c)(3) nonprofit operating both domestically and internationally, VHI recognizes its legal and moral obligation to protect individuals who report suspected misconduct, violations of law, or breaches of organizational policy.

This Whistleblower Policy is established in accordance with applicable U.S. federal laws—including the Sarbanes-Oxley Act and IRS guidelines for exempt organizations, California state laws governing nonprofit integrity and employee protections, and internationally recognized principles of safeguarding and anti-retaliation. It applies to all employees, volunteers, board members, contractors, and affiliated partners across VHI’s global programs.

VHI encourages the prompt reporting of concerns related to financial mismanagement, fraud, abuse, harassment, child protection violations, or any other unethical or unlawful behavior. All reports will be handled confidentially, investigated thoroughly, and addressed appropriately. Retaliation against whistleblowers is strictly prohibited and will result in disciplinary action, up to and including termination or legal referral.

By codifying these protections, VHI affirms its commitment to creating a safe and responsive environment where every stakeholder can speak out without fear, ensuring that our mission to serve vulnerable children and families is carried out with integrity, dignity, and legal compliance.

 

02. Scope

This Whistleblower Policy applies to all individuals and entities associated with Village Hope International (VHI), including but not limited to:

  • Employees (full-time, part-time, and temporary).

  • Volunteers and interns.

  • Board members and officers.

  • Contractors, consultants, and vendors.

  • Program partners and affiliated organizations.

  • Beneficiaries and community stakeholders.

The policy covers concerns related to actual or suspected:

  • Violations of U.S. federal, California state, or international laws and regulations applicable to nonprofit organizations.

  • Breaches of VHI’s internal policies, including financial management, child protection, nondiscrimination, and safeguarding standards.

  • Fraud, corruption, theft, or misuse of organizational assets.

  • Harassment, abuse, exploitation, or other forms of misconduct.

  • Retaliation against individuals who report concerns in good faith

This policy applies across all VHI programs, offices, and operational contexts, whether in the United States or abroad and is designed to ensure consistent protection and accountability regardless of jurisdiction. It complements VHI’s broader compliance framework and reinforces our commitment to lawful, ethical, and transparent conduct in every community we serve.

 

03. Definitions

For the purposes of this Whistleblower Policy, the following terms are defined as follows:

Whistleblower:

Any individual who, in good faith, reports suspected misconduct, unethical behavior, or violations of law or policy within Village Hope International. This includes employees, volunteers, board members, contractors, beneficiaries, and external stakeholders.

Good Faith Report:

A disclosure made with honest intent, based on a reasonable belief that the information disclosed indicates a violation of law, regulation, or organizational policy. Reports made with malicious intent or knowingly false information are not protected under this policy.

Misconduct:

Any action or omission that violates applicable laws, regulations, internal policies, or ethical standards. This includes, but is not limited to, fraud, theft, corruption, abuse, harassment, exploitation, discrimination, and breaches of child protection protocols.

Retaliation:

Any adverse action taken against a whistleblower as a result of their report. This includes termination, demotion, harassment, exclusion, threats, or any form of intimidation. Retaliation is strictly prohibited under U.S. federal law (e.g., Sarbanes-Oxley Act), California Labor Code Section 1102.5, and international safeguarding norms.

Confidentiality:

The obligation to protect the identity of the whistleblower and the details of the report to the fullest extent possible, consistent with the need to conduct a fair and thorough investigation and comply with legal obligations.

Designated Officer:

The individual(s) appointed by Village Hope International to receive, assess, and manage whistleblower reports. This may include the Executive Director, Compliance Officer, or an independent third-party reporting channel.

Protected Disclosure:

Any report made under this policy that qualifies for legal protection against retaliation under applicable U.S., California, or international laws.

 

04. Reporting Procedures

Village Hope International (VHI) encourages all individuals covered under this policy to report suspected misconduct, unethical behavior, or violations of law or organizational policy promptly and in good faith. Reports may be submitted through any of the following channels:

Internal Reporting Channels

  • Designated Officer: Reports may be submitted directly to VHI’s designated Whistleblower Officer, currently the Executive Director or their appointed delegate.

  • Board Oversight: Concerns involving senior leadership or governance may be directed to the Chair of the Board or the designated Compliance Committee.

  • Written Reports: Reports may be submitted in writing via email or sealed envelope marked “Confidential – Whistleblower Report.”

Anonymous Reporting

  • VHI permits anonymous reporting through secure third-party platforms or designated drop boxes, where available.

  • While anonymity is respected, providing sufficient detail is essential to enable a thorough investigation.

External Reporting

Individuals may report concerns to external authorities where legally required or appropriate, including:

  • U.S. Internal Revenue Service (IRS) for nonprofit compliance violations.

  • California Attorney General’s Registry of Charitable Trusts.

  • Law enforcement or child protection agencies in relevant jurisdictions.

  • International oversight bodies or local regulatory authorities, where applicable

Content of the Report

To facilitate effective review, reports should include:

  • A clear description of the alleged misconduct.

  • Names of individuals involved (if known).

  • Dates, locations, and relevant documentation (if available).

  • Any steps already taken to address the concern.

Acknowledgment and Follow-Up

  • VHI will acknowledge receipt of all reports within five (5) business days, where contact information is provided.

  • The Designated Officer will initiate a preliminary review and determine whether a formal investigation is warranted.

  • Whistleblowers will be informed of the outcome to the extent legally and operationally appropriate.

 

05. Investigation Process

Village Hope International (VHI) is committed to conducting timely, fair, and thorough investigations of all whistleblower reports submitted in good faith. The following procedures govern the investigation process:

Preliminary Review

  • Upon receipt of a report, the Designated Officer will conduct a preliminary review to assess credibility, scope, and potential legal or policy implications.

  • If the report involves senior leadership or board members, the matter will be referred to the Board Chair or an independent compliance delegate.

Initiation of Formal Investigation

  • If warranted, a formal investigation will be initiated within ten (10) business days of the preliminary review.

  • Investigations may be conducted internally or by an independent third party, depending on the nature and severity of the allegation.

Investigation Standards

All investigations will be conducted in accordance with applicable U.S. federal laws (e.g., Sarbanes-Oxley Act), California nonprofit and labor regulations, and international safeguarding standards. Investigators will ensure:

  • Impartiality and objectivity.

  • Confidentiality of all parties involved.

  • Protection of whistleblower identity to the extent legally permissible.

  • Preservation of evidence and documentation.

Findings and Outcomes

  • Upon conclusion, a written report will summarize findings, determine whether misconduct occurred, and recommend corrective actions.

  • The report will be submitted to the Executive Director and/or Board Oversight Committee, as appropriate.

  • Corrective actions may include disciplinary measures, policy revisions, legal referrals, or other remedial steps.

Notification and Follow-Up

  • Where appropriate and legally permissible, whistleblowers will be informed of the outcome and any actions taken.

  • VHI will monitor implementation of corrective measures and ensure resolution is documented.

Record keeping

All investigation records will be securely maintained for a minimum of seven (7) years in compliance with IRS and California record retention requirements.

 

06. Non-Retaliation and Confidentiality

Village Hope International (VHI) strictly prohibits retaliation against any individual who, in good faith, reports suspected misconduct, unethical behavior, or violations of law or organizational policy. Retaliation includes, but is not limited to:

  • Termination, demotion, or suspension.

  • Harassment, intimidation, or exclusion.

  • Adverse changes in duties, compensation, or working conditions.

  • Threats or coercion of any kind.  

Any act of retaliation will be treated as a serious violation of this policy and may result in disciplinary action, up to and including termination, legal referral, or removal from partnership or board service. VHI complies fully with U.S. federal protections under the Sarbanes-Oxley Act, California Labor Code §1102.5, and international safeguarding norms that protect whistleblowers from reprisal.

Confidentiality

VHI is committed to maintaining the confidentiality of whistleblower reports to the maximum extent possible, consistent with the need to conduct a fair and thorough investigation and comply with applicable legal obligations. Specifically:

  • The identity of the whistleblower will not be disclosed without their consent, unless required by law or necessary for investigative integrity.

  • All documentation and communications related to the report will be handled securely and discreetly.

  • Investigative findings will be shared only with those who have a legitimate need to know. 

Whistleblowers are encouraged to provide sufficient detail to support effective investigation while trusting that their privacy and protection are prioritized throughout the process.

 

07. Oversight and Review

Village Hope International (VHI) maintains rigorous oversight of this Whistleblower Policy to ensure its effectiveness, legal compliance, and alignment with the organization’s mission and values. Oversight responsibilities are structured as follows:

Board Governance

  • The Board of Directors holds ultimate responsibility for the integrity and enforcement of this policy.

  • The Board shall designate a Compliance Committee or Officer to monitor implementation, review investigation outcomes, and ensure appropriate corrective actions are taken.

  • Any reports involving senior leadership or board members shall be escalated directly to the Board Chair or an independent delegate for impartial review.

Executive Oversight

  • The Executive Director is responsible for operationalizing the policy, ensuring staff awareness, and supporting a culture of transparency and non-retaliation.

  • The Executive Director shall report quarterly to the Board on whistleblower activity, including the number of reports received, types of concerns raised, and resolution status, while maintaining confidentiality.

Policy Review and Updates

This policy shall be reviewed annually by the Board or designated Compliance Committee to ensure continued compliance with:

  • U.S. federal laws and IRS requirements for exempt organizations.

  • California nonprofit and labor regulations.

  • International safeguarding and anti-retaliation standards.

  • Updates shall be made as needed to reflect changes in law, organizational structure, or operational context.

Audit and External Review

  • VHI may engage external auditors or legal counsel to periodically assess the effectiveness of whistleblower protections and investigative procedures.

  • Findings and recommendations shall be presented to the Board for action and documented in governance records.

 

08. Policy Acknowledgment and Training

Village Hope International (VHI) ensures that all individuals covered under this Whistleblower Policy are informed of their rights, responsibilities, and protections through structured onboarding, ongoing training, and formal acknowledgment procedures.

Acknowledgment of Policy

  • All employees, volunteers, board members, and contractors shall receive a copy of this policy upon engagement with VHI.

  • Individuals must sign a written acknowledgment confirming that they have read, understood, and agreed to comply with the policy.

  • Acknowledgment forms shall be retained in personnel or governance files in accordance with VHI’s recordkeeping protocols and applicable legal requirements.

Training and Awareness

VHI shall provide annual training on whistleblower protections, reporting procedures, and non-retaliation standards to all staff, volunteers, and board members.

Training shall be tailored to the operational context (U.S., California, or international) and include:

  • Examples of reportable misconduct.

  • How to submit a report confidentially or anonymously.

  • Legal protections under U.S. federal law, California statutes, and international safeguarding norms.

  • VHI’s commitment to child protection, ethical conduct, and transparency.

  • Specialized training shall be provided to designated officers, investigators, and compliance personnel responsible for managing reports.

Global Accessibility

  • VHI shall ensure that whistleblower training and materials are accessible across all program sites, including translations and culturally appropriate formats where needed.

  • Beneficiaries and community stakeholders shall be informed of their right to report concerns through safe and trusted channels.

Continuous Improvement

  • Feedback from training sessions and whistleblower experiences shall be used to improve policy implementation and organizational culture.

  • VHI shall periodically review training content to reflect changes in law, risk environment, and operational scope.

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