Whistleblower Policy

This whistleblower policy of the Investment Program Association (the “Association”) (a) encourages staff and volunteers to come forward in good faith with credible information on illegal practices or serious violations of adopted policies of the Association, (b) specifies that the Association will protect the person from retaliation, and (c) identifies where such information can be reported.

Encouragement of Reporting. The Association encourages complaints, reports or inquiries about illegal practices or serious violations of the Association’s policies, including illegal or improper conduct by the Association itself, by its leadership, or by others on its behalf. Appropriate subjects to raise under this policy would include financial improprieties, accounting or audit matters, ethical violations, or other similar illegal or improper practices or policies. However, this policy does not apply to personnel matters, such as allegations of discrimination or harassment, which should be pursued via the Association’s human resources channels and any related employment policies.

Protection from Retaliation. The Association prohibits retaliation by or on behalf of the Association against staff or volunteers for making good faith complaints, reports or inquiries under this policy or for participating in a review or investigation under this policy. This protection extends to those whose allegations are made in good faith but prove to be mistaken. The Association reserves the right to discipline persons who make bad faith, knowingly false, or vexatious complaints, reports or inquiries or who otherwise abuse this policy.

Where to Report. Complaints, reports or inquiries should describe in detail the specific facts demonstrating the bases for the complaints, reports or inquiries. They should be directed to the President or Chairman of the Association. If both of those persons are implicated in the complaint, report or inquiry, it should be directed to the Treasurer or Secretary of the Association.