Whistleblower Policy

Purpose

The Transgender Healthcare Access Fund (THAF) is committed to maintaining the highest standards of ethical conduct and compliance with all applicable laws and regulations. This Whistleblower Policy is designed to encourage and enable employees, volunteers, board members, and others to raise serious concerns internally so that THAF can address and correct inappropriate conduct and actions.

Scope

This policy applies to all employees, volunteers, board members, contractors, vendors, and other individuals performing services for or on behalf of THAF. It covers reports of suspected misconduct including, but not limited to: violations of federal, state, or local laws, regulations, or organizational policies; fraud, theft, embezzlement, or financial misconduct; abuse, misuse, or waste of organizational resources, funds, or assets; discrimination, harassment, or hostile work environment based on protected characteristics; dangerous workplace conditions or violations of health and safety standards; conflicts of interest or self-dealing; retaliation against individuals who report suspected misconduct or participate in investigations; falsification of records or documents; and any other conduct that could harm THAF's mission, reputation, operations, or tax-exempt status.

Reporting Procedures

Individuals who wish to report suspected misconduct may do so through the following channels, depending on the nature of the concern and the individuals involved: reporting to their direct supervisor or manager, provided that the supervisor or manager is not the subject of the report; contacting the Executive Director via email at ed@thafund.org or through other designated contact methods; contacting the Board Chair or any member of the Board of Directors, particularly when the concern involves the Executive Director or other senior leadership; or submitting an anonymous report through designated channels established by THAF for confidential reporting. Anonymous reports will be taken seriously and investigated to the extent possible, though the ability to investigate may be limited if sufficient detail is not provided.

Reports may be made via email, telephone, in writing, or in person. Contact information for reporting concerns is available to all employees, volunteers, board members, contractors, and vendors. Reports should include as much detail as possible regarding the suspected misconduct, including dates, locations, individuals involved, witnesses, and any evidence or documentation supporting the concern. Individuals making reports are encouraged to provide their contact information to facilitate follow-up and investigation, though anonymous reports will also be accepted and reviewed.

Protection Against Retaliation

THAF strictly prohibits retaliation of any kind against individuals who report suspected misconduct in good faith. This protection extends to and includes individuals who: report concerns internally or externally; participate in investigations, whether as witnesses, subjects, or otherwise; refuse to participate in activities they reasonably believe to be illegal, unethical, or in violation of organizational policies; or provide information or assistance in connection with an investigation. Retaliation includes, but is not limited to: termination, suspension, demotion, or reduction in responsibilities or compensation; harassment, intimidation, threats, or hostile treatment; blacklisting or interference with future employment opportunities; and any other adverse action that would discourage a reasonable person from reporting concerns or participating in investigations.

Retaliation is a serious violation of this policy and applicable law, and will result in disciplinary action, up to and including immediate termination of employment or service, removal from the organization, and potential legal action. Any individual who believes they have been subjected to retaliation in violation of this policy should immediately report such retaliation using the same reporting procedures outlined above. All retaliation reports will be promptly and thoroughly investigated.

Investigation Process

All reports of suspected misconduct will be investigated promptly, thoroughly, fairly, and impartially. The investigation will be conducted by appropriate personnel, which may include the Executive Director, Board members, a designated committee, or external independent investigators, depending on the nature and severity of the concern and the individuals involved. Investigations will be conducted in a manner that protects the rights of all parties, including the reporting individual, any subjects of the report, and any witnesses. Investigators will gather and review relevant documents, interview appropriate individuals, and take such other steps as necessary to determine the facts and circumstances surrounding the reported misconduct.

Confidentiality will be maintained to the extent possible, consistent with the need to conduct an adequate investigation and comply with legal obligations. Information relating to investigations will be shared only with those individuals who have a legitimate need to know. The reporting individual will be informed of the outcome of the investigation as appropriate, subject to privacy and confidentiality considerations. If the investigation substantiates that misconduct has occurred, appropriate corrective and disciplinary action will be taken, up to and including termination of employment or service, removal from the organization, restitution, and referral to law enforcement authorities if warranted.

Bad Faith Reports

While THAF encourages reporting of genuine concerns, individuals who knowingly make false or malicious reports may be subject to disciplinary action. This policy is not intended to protect those who make reports in bad faith.

Policy Review

This policy will be reviewed annually by the Board of Directors and updated as necessary to ensure its effectiveness and compliance with applicable laws.