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Field Whistleblower Policy: Reporting and Rights

SCORE Staff
  • Updated

Effective Date:

Monday, September 12, 2022

 

Applicability:

This policy applies to SCORE Volunteers

 

Please note, SCORE volunteers wishing to file a complaint or raise a concern related to SCORE’s operational management practices or personnel issue (e.g. behavior of a volunteer) should submit those complaints to help@SCORE.org. These types of complaints will be resolved in accordance with SCORE’s Field Policies and Procedures.

 

The procedures set forth below describe the reporting procedures for suspected fraudulent, unethical or dishonest conduct (including suspected waste, fraud, or abuse of federal award funds).

Policy:

Criminal Whistleblower Code of Conduct

In keeping with the policy of maintaining the highest standards of conduct and ethics, SCORE will investigate any suspected fraudulent or dishonest use or misuse of SCORE’s resources or property by staff, board members, consultants or volunteers. SCORE is committed to maintaining the highest standards of conduct and ethical behavior and promotes a working environment that values respect, fairness and integrity. All staff, board members and volunteers shall act with honesty, integrity and openness in all their dealings as representatives for the organization. Failure to follow these standards will result in disciplinary action including possible termination and possible civil or criminal prosecution if warranted.

Reporting a Concern

Method 1: Reporting to the SCORE Board of Directors

When to Use this Reporting Method

An individual should use this method of reporting when they have concerns about possible fraudulent or dishonest conduct. This may include the suspected misuse of non-Federal award funds, or a concern that a SCORE Executive is intentionally acting an unethical manner.

 

How to Report via this Method

Concerns should be reported the Secretary of the SCORE Board of Directors. A reporter should Contact the SCORE Compliance Manager who will provide the relevant contact details in an efficient and discreet manner. Full details of the concern should only be shared with SCORE Board members and not with SCORE employees or volunteers.

 

Alternatively, to facilitate reporting of suspected violations where the reporter wishes to remain anonymous, a written statement may be submitted to the Secretary of the SCORE Board of Directors by addressing the written correspondence as follows:

 

ATTN: SCORE Secretary of the SCORE Board – Sensitive Enclosure

1165 Herndon Parkway

Suite 100

Herndon, VA 20170

 

Correspondence received in this way will be delivered to the current SCORE Secretary without being opened by SCORE Staff.

 

Investigation Procedure

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. Appropriate corrective action will be taken, at the discretion of the SCORE Board of Directors, and findings will be communicated back to the reporting person. Investigations may warrant investigation by an independent person such as auditors and/or attorneys.

 

Rights and Protections for the Whistleblower

SCORE will protect whistleblowers as defined below:

 

SCORE will use its best efforts to protect whistleblowers against retaliation. Whistleblowing complaints will be handled with sensitivity, discretion and confidentiality to the extent allowed by the circumstances and the law. Generally this means that whistleblower complaints will only be shared with those who have a need to know so that SCORE can conduct an effective investigation, determine what action to take based on the results of any such investigation, and in appropriate cases, with law enforcement personnel. (Should disciplinary or legal action be taken against a person or persons as a result of a whistleblower complaint, such persons may also have right to know the identity of the whistleblower.)

 

Whistleblowers who believe that they have been retaliated against may file a written complaint with the Secretary of the Board of Directors (see Reporting Method 1 above). Any complaint of retaliation will be promptly investigated and appropriate corrective measures taken if allegations of retaliation are substantiated. This protection from retaliation is not intended to prohibit supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.

 

Whistleblowers must be cautious to avoid baseless allegations (as described in the definitions section of this policy).

 

Method 2: Reporting to the US Small Business Administration (SBA) Office of Inspector General (OIG) Hotline

When to Use this Reporting Method

An individual should use this method of reporting when there is suspected potential waste, fraud, or abuse of SCORE property or federal award resources.

 

How to Report via this Method

Concerns should be reported the OIG Hotline:

 

OIG Hotline at 1-800-767-0385 or

OIGHotline@sba.gov

 

Please note: Federal law protects all whistleblowers from retaliation.

 

Responsibilities of SCORE Volunteers and Volunteer Leaders

SCORE Volunteers are encouraged to report suspected fraudulent or dishonest conduct to the Secretary of the Board of Directors (via Reporting Method 1). This includes reporting any fraudulent or dishonest conduct that may have been report to the SCORE volunteer by another SCORE volunteer, client, employee, or member of the general public.

 

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

  • baseless allegations;
  • premature notice to persons suspected of misconduct and/or disclosure of suspected misconduct 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 violations, effective professional

follow-up is critical. SCORE volunteers, while appropriately concerned about “getting to the bottom”

of such issues, should not in any circumstances perform any investigative or other follow up

steps on their own. Accordingly, a SCORE volunteer who becomes aware of suspected misconduct:

  • should not contact the person suspected to further investigate the matter or demand restitution.
  • should not discuss the case with attorneys, the media or anyone other than any member of the Board of Directors.
  • should not report the case to an authorized law enforcement officer without first discussing the case with a member of the SCORE Board of Directors.

Definitions

Abuse

Abuse is the intentional destruction, diversion, manipulation, misapplication, mistreatment, or misuse of SCORE’s Federal Award resources; the profligate or improper use of SCORE property; or the extravagant or improper use of a person’s position or authority.  Abuse can occur in a financial or non-financial environment.

 

Examples:

  • Writing technical specifications or contract terms to favor a specific contractor.
  • Abusing one’s authority or position.
  • Soliciting or accepting gifts.
  • Deliberately or recklessly damaging or improperly maintaining equipment owned or leased by the SCORE.

 

Baseless Allegations

Allegations made with reckless disregard for their truth or falsity. People

making such allegations may be subject to disciplinary action by SCORE, and/or legal claims by

individuals accused of such conduct.

 

Fraud

Fraud is an intentional misrepresentation of material fact made to another person with knowledge of its falsity for the purpose of inducing the other person to act, and upon which the other person relies and consequently suffers injury or damage.

 

Examples:

  • Embezzling or other financial irregularities.
  • Forging, improperly altering, or falsifying documents.
  • Falsely reporting hours or days worked.
  • Buying overpriced office equipment from a favored vendor.
  • Buying unnecessary equipment for personal use or gain.
  • Receiving or offering bribes or kickbacks.

 

Fraudulent or Dishonest Conduct

A deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples of such conduct include, but are not limited to:

  • forgery or alteration of documents;
  • unauthorized alteration or manipulation of computer files; fraudulent financial reporting;
  • pursuit of a benefit or advantage in violation of SCORE’s Conflict of Interest Policy;
  • misappropriation or misuse of SCORE’s resources, such as funds, 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

 

Waste

Waste is considered the unnecessary spending or squandering of SCORE’s Federal resources, whether intentional or unintentional. Inefficient or ineffective practices may result in waste.

 

Examples:

  • Stockpiling equipment or supplies beyond their shelf-life.
  • Renewing a technical support contract for something SCORE no longer uses
  • Excessive copying or printing of documents.

 

Whistleblower

An employee, consultant or volunteer who informs the Board of Directors about an activity relating to

SCORE which that person believes to be fraudulent or dishonest.

Policy Owner:

SCORE Compliance Manager

Related Policies and Procedures:

Federal Authorities:

The Sarbanes-Oxley Act

The Sarbanes-Oxley Act which was signed into law on July 30, 2002, was designed to add new governance standards for the corporate sector to rebuild public trust in publicly held companies. While the majority of this act deals directly with for profit organizations, two standards in the act, document destruction and whistleblower protection, cover non-profit organizations.

 

Standard Term #32 of the SCORE Program’s Terms and Conditions

Administered by the US Small Business Administration (SBA).

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