1.1.6 Whistleblower Policy

POLICY TYPE: 1.0 Administrative Policies \ 1.1 Fair Treatment
EFFECTIVE DATE: 2019-03-21	LAST REVISED: 2025-12-09
THIS POLICY APPLIES TO: Contractors – Individuals engaged to provide services under a contract with SelfDesign Learning Foundation Support Providers – Individuals engaged under a contract or agreement with SelfDesign Learning Foundation to provide services for a specific learner Families – Learners and parents(s)/guardian(s) of learners participating in SelfDesign Learning Foundation’s programs Volunteers – Individuals providing goods/services under the terms of an agreement with SelfDesign Learning Foundation Board Members – Members of the Board of Directors for SelfDesign Learning Foundation and the Foundation for SelfDesign (FSD)

Policy Statement

SelfDesign Learning Foundation (SDLF) is committed to fostering a culture of transparency, accountability, and ethical conduct. This Whistleblower Policy is designed to provide a clear and safe process for individuals to report concerns about suspected wrongdoing, misconduct, or other breaches of the law or our organizational policies, without fear of retaliation.

SDLF encourages the reporting of such concerns in good faith and is committed to ensuring that anyone who raises a concern is protected from retaliation. We recognize the courage it may take to speak up, and we are committed to listening, responding appropriately, and addressing issues with fairness and care.

This policy outlines the principles and procedures for reporting, investigating, and responding to concerns, in alignment with our values of integrity, accountability and relationship.

Definitions

Retaliation – Retaliation in this context refers to negative actions taken against an employee/contractor for engaging in a protected activity, such as filing a complaint or participating in an investigation. Actions taken by a chief, director, or lead that are related to the normal and reasonable management of the workplace or if a contractor faces a negative outcome due to a legitimate, documented performance issue are not considered retaliation.

Whistleblower – a person who reports (or ‘blows the whistle’) on improper conduct within an organization.

Policy

SelfDesign Learning Foundation will investigate in a timely manner and take corrective action against any serious violation of its policies and responsibilities. When a learner, family, contractor, volunteer, or representative of SDLF (a “complainant’’) has reasonable grounds to believe that a contractor, volunteer, or representative of SDLF has committed, or is about to commit, financial, or other, wrongdoing, the following applies:

The complainant should disclose this information through the process set out in this policy. The complainant will be protected from reprisals.
The subject of the complaint (the “respondent”) will be provided with an opportunity to respond to the allegations.
All parties to an investigation will be treated fairly and equitably.
Confidentiality will be maintained to the greatest extent possible.
If wrongdoing is found, appropriate remedial and corrective actions will be taken.

Protocol

Confidentiality

SDLF will keep a complaint, the complainant’s identity, the respondent’s identity, witness identities and witness statements confidential to the extent reasonably possible, subject to any disclosure requirements under applicable legislation and consistent with the need to conduct an adequate investigation.

False and Malicious Allegations

Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious offence and appropriate disciplinary actions will be taken.

File Management and Record Keeping

A record of all complaints received will be retained on file by the CEO and/or the Board, as applicable. Files will include the original complaints as well as all other relevant notes and documents, such as signed and dated testimonies, and investigation reports. The files will be kept separate from contractor personnel files.

Improper Conduct or Wrongdoing

Includes, but is not limited to, activities that:

Are unlawful or not in compliance with any laws or regulations to which SDLF is subject;
Do not adhere to SDLF’s accounting and internal control procedures and policies;
Do not adhere to SDLF’s policies, especially bullying and harassment policies, or any other program/department operating policies and protocols;
May amount to fraud or corruption;
Reflect a real or perceived conflict of interest;
Represent the unauthorized use or misuse of SDLF funds or property; or
Otherwise constitutes unethical or improper conduct or abuse.

Reporting Responsibility and Investigation Process

Anyone with concerns or complaints regarding improper activities as listed within this policy, is expected to share their concerns by submitting a written statement, with supporting evidence attached, to the CEO of SDLF. The written report may be submitted:

Via email to ceo@selfdesign.org
By mail to the CEO:

CEO – PRIVATE & CONFIDENTIAL
SelfDesign Learning Foundation
PO Box 74560 RPO Kitsilano
Vancouver, BC V6K 4P4
Canada

If the complaint concerns bullying and harassment, please refer to the Workplace Bullying and Harassment Policy.

In the event that the complaint pertains to the CEO, the complaint should be made in writing to the SDLF Board Chair and the Treasurer. The Board of Directors will either conduct their own investigation and communication process or the Board of Directors may, at their own discretion, contract a third-party to conduct and complete the investigation. The written report may be submitted:

Via email to the SDLF Board Chair and Treasurer at board@selfdesign.org

Once a complaint is received:

In the event that a complaint requires immediate action because of a significant health or safety concern, or if the issue behind the complaint can damage the organization’s reputation, SDLF will take immediate necessary action, and then continue with the steps in this policy.

When SDLF receives the complaint, they will:

Inform the Board Chair immediately.
Provide the complainant with a written acknowledgement of receipt within 5 business days of receiving the complaint.
Investigate the complaint and take any action necessary to address the subject matter of the complaint. This action could include the appointment of a designated investigator who could be internal or external to the organization. SDLF anticipates that many concerns may be sufficiently addressed through informal, common problem-solving processes with the complainant and the respondent. However, SDLF may opt for a formal investigation depending on the nature of the complaint.
Within 30 calendar days of receiving the complaint, provide a written report to the complainant addressing the complaint and any action taken. If SDLF has reached a conclusion on the complaint by that time, either by informal resolution or an investigation, the report will include a summary of the following:
1. The allegations as presented by the complainant;
2. A brief statement of all relevant findings of fact, subject to privacy laws; and the evidence relied upon in reaching any conclusions
3. The conclusion reached and the basis for those conclusions.

If SDLF has not completed its review and/or investigation within 30 days, it will provide a written report to the complainant explaining the steps taken at that time, and the anticipated timeline for the delivery of a written report summarizing its findings and conclusion. SDLF will proceed as expediently as possible.

Upon completion of the written report, the Board of Directors will be notified. Conclusions for all complaints will be summarized and shared by the CEO in quarterly updates to the Board of Directors.

No Retaliation

No person who files a complaint shall suffer retaliation. A contractor, volunteer, or SDLF representative who retaliates against someone who has reported a complaint in good faith is subject to discipline up to and including termination of a contract or association with SDLF. Conversely, anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the SDLF’s legal, financial, regulatory, and ethical responsibilities.

Principles of Fair Investigation

Impartiality and objectivity are to be observed throughout an investigation. This serves to protect the rights of everyone involved and will help enhance public confidence in the process. The following will be observed:

All relevant parties must be informed of the complaint and have the opportunity to be heard and have their submissions considered.
The investigator must be impartial in assessing the credibility of the respondents/witnesses. Where appropriate, conclusions as to credibility should be included in the investigation report.
The investigator will not have a personal or other interest in the complaint being investigated that would create real or perceived bias.
An investigation may, at the discretion of the President and CEO, and/or the SDLF Board Chair, be conducted by an individual internal or external to SDLF.

Protecting the Respondent (the Person who is the Subject of a Complaint)

The welfare of the respondent should be considered, and steps will be taken to avoid unnecessary harm to that person. Their identity will be kept confidential, subject to any disclosure requirements under applicable law, to the extent reasonably possible. At a respondent’s request, SDLF will reasonably facilitate support for the respondent during an investigation, either through an internal contact or, if required, an external/third-party appointed and/or contracted by SDLF.