whistleblower policy

All Venice Arts staff, as well as its Board of Directors, shall be provided the following policy relevant to the ethical and legal conduct of employees, Directors, and the organization as a whole.

1.     Whistleblower Policy

Venice Arts’ Whistleblower Policy has been designed to:

  • Prevent or detect and correct improper activities

  • Encourage each Board member, director, and employee to report what he or she in good faith believes to be a material violation of law or policy or questionable accounting or auditing matter by Venice Arts

  • Ensure the receipt, documentation, retention of records, and resolution of reports received under this policy protect reporting individuals from retaliatory action

a.     Reporting Responsibility

Each reporting individual has an obligation to report what he or she believes is a material violation of law or policy or any questionable accounting or auditing matter by Venice Arts, its officers, directors, employees, or other representatives. Reporters must notify the President of Venice Arts’ Board of Directors if an action needs to be taken in order for Venice Arts to be in compliance with law, policy, or generally accepted accounting practices. Concerns to be reported include, but are not limited to:

  • Providing false or misleading information on the Venice Arts’ financial documents, grant reports, tax returns or other public documents

  • Providing false information to or withholding material information from the Venice Arts’ auditors, accountant, lawyers, directors or other representatives responsible for ensuring compliance with fiscal and legal responsibilities

  • Embezzlement, private benefit, or misappropriation of funds

  •  Material violation of Venice Arts’ policy, including among others, confidentiality, conflict of interest, whistleblower, ethics, and document retention

  •  Discrimination based on race, gender, sexual orientation, ethnicity, and disability

  • Facilitation or concealing any of the above or similar actions

b.     Reporting Concerns

Whenever possible, an employee should seek to resolve concerns by reporting issues directly to his/her supervisor or to the next level of management as needed until matters are satisfactorily resolved. However, if for any reason an employee is not comfortable speaking to a supervisor or does not believe the issue is being properly addressed, the employee may contact the Executive Director. If the Executive Director is the Supervisor and the reporting employee feels that her/his concerns are not adequately addressed, she/he should contact the President of the Board of Directors. If for any reason the aforementioned communication lines are not a possibility, the employee should contact the third party administered “Fraud Hotline”.  

The Fraud Hotline specializes in forensic auditing, fraud examination and asset misappropriation when and if these matters are in question or suspicion. Any Venice Arts’ employee with serious concerns of violation of law or policies should contact the Fraud Hotline via email or phone, as noted below. Both the website and telephone call are confidential. Personally identifiable information about the reporter is not released unless the individual gives approval.  

  • Contact by email: www.report-fraud.com. The website is self-explanatory as to reporting process and assists the reporter to submit relevant documents, pictures or other evidence.

  •  Contact by phone at 1-877-637-2830. The toll-free hotline number will connect directly to a private voicemail monitored by a fraud examiner who is not employed by Venice Arts.

a.       Handling of Reported Violations

Venice Arts will investigate all reports filed in accordance with this policy. Matters reported internally without initial resolution will be investigated by the Executive Director, or Board Executive Committee, to determine if the allegations are true, whether the issue is material and what actions, if any, are necessary to correct the problem. The Executive Director or Executive Committee will issue a full report of all matters raised under this policy to the Board of Directors. The Board of Directors may conduct a further investigation upon receiving the report from the Director.

For matters reported directly to the Board Executive Committee, the Board shall promptly acknowledge receipt of the complaint to the complainant if the identity of the complainant is known, conduct an investigation to determine if the allegations are true and whether the issue is material, and if determinable what, if any, corrective action is necessary. Upon the conclusion of this investigation, the Board of Directors shall promptly report its findings to all pertinent parties. For those matters reported to the Fraud Hotline, an independent examiner will evaluate the information given and contact Venice Arts’ Executive Director where a course of action will be determined.

c.      Authority of Investigative Parties

The Investigative Parties shall have full authority to investigate concerns raised in accordance with this policy and may retain outside legal counsel, accountants, private investigators, or any other resource that is necessary to conduct a full and complete investigation of the allegations.

d.     No Retaliation

This Whistleblower Policy is intended to encourage and enable employees to raise serious concerns within the organization for investigation and appropriate action. With this goal in mind, no employee who, in good faith, reports a concern shall be threatened, discriminated against or otherwise subject to retaliation or suffer adverse employment consequences as a result of such report. An employee who retaliates against a reporter acting in good faith is subject to discipline up to and including suspension without pay or termination of employment.

e.     Acting In Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a serious violation of law or policy or a material accounting or auditing. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, with gross negligence, 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 suspension without pay or termination of employment. Depending on the circumstances, such conduct may give rise to other actions, including civil or criminal lawsuits as determined by the Board of Trustees or any other individual who may have a private cause of action against the reporter.

f.      Confidentiality

Reports of concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible. However, consistent with the need to conduct an adequate investigation, Venice Arts cannot guarantee complete confidentiality. Disclosure of information related to an investigation under this policy by staff, directors, or others involved with the investigation of Venice Arts to individuals not involved in the investigation will be viewed as a serious disciplinary offense and, with respect to Venice Arts’ employees, may result in discipline, up to and including suspension without pay or termination of employment. Depending on the circumstances, such conduct may also give rise to other actions, including civil or criminal lawsuits.