Whistleblower Protection Policy

The Montana Library Association (MLA) requires directors, officers and independent contractors to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As independent contractors and representatives of MLA, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This whistleblower policy is intended to encourage and enable independent contractors and others to raise serious concerns internally so that MLA can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, independent contractors and volunteers to report concerns about violations of MLA’s code of ethics or suspected violations of law or regulations that govern MLA’s operations.

No Retaliation

It is contrary to the values of MLA for anyone to retaliate against any board member, officer, independent contractor, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of MLA. An independent contractor who retaliates against someone who has reported a violation in good faith is subject to discipline up to, and including, termination of employment.

Reporting Procedure

MLA has an open-door policy and suggests that independent contractors share their questions, concerns, suggestions, or complaints with the MLA President. If you are not comfortable speaking with the president or you are not satisfied with the president’s response, you are encouraged to speak with the MLA Executive Director or a board member. The president and executive director are required to report complaints or concerns about suspected ethical and legal violations in writing to MLA’s Secretary-Treasurer who has the responsibility to investigate all reported complaints. Independent contractors with concerns or complaints may also submit their concerns in writing directly to the president, the executive director, or the secretary-treasurer.

Compliance Officer

MLA’s Audit Committee Chair is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The chair of the audit committee will advise and report at least annually to the executive director and/or the board of directors of all complaints and their resolution and compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

MLA’s Secretary-Treasurer shall immediately notify the audit committee of any concerns or complaints regarding corporate accounting practices, internal controls or auditing, and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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 disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

MLA’s Audit Committee Chair will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Adopted June 21, 2017