EDF WHISTLEBLOWING POLICY

INTRODUCTION

The Education for Democracy Foundation (EDF) is a non-governmental organization, not affiliated with political parties, churches and religious associations. The statutory goal of the Foundation is to initiate, support and conduct educational activities aimed at promoting the idea of ​​democracy and preparing people to contribute to democracy and to act in democratic institutions. The Foundation’s activities are guided by integrity, responsibility, reliability and transparency to ensure the highest quality of activities undertaken. EDF cooperates with people of various nationalities, religions and political beliefs.

The Foundation’s Management Board fully supports the policy of reporting irregularities (whistleblowing policy) adopted by the Foundation and ensures that all reports will be carefully considered, and if the allegations contained therein are confirmed, the Management Board will apply disciplinary measures to the appropriate persons.

REPORT A CONCERN

Any person associated with EDF or who has knowledge of irregularities and abuses or inappropriate behavior on the part of our employees, or during the implementation of activities financed by the EDF may file a complaint or report an irregularity. EDF will acknowledge receipt of the complaint within 5 working days and inform the whistleblower about the initial steps taken. 

If there are grounds to reasonably suspect that criminal activity took place the appropriate national authorities should be contacted directly.

Complaints and reports on irregularities are accepted in writing:

 

Complaints and irregularities reports should include:

  • a detailed description of the case,
  • personal data of the person submitting the complaint – name, surname (entity name), correspondence address (as a general rule anonymous complaints don’t have to be investigated, although EDF is committed to investigating anonymous complaints if possible).

 

The identity of the person or persons raising concerns will be kept confidential as far as possible. It is not always possible to keep complete confidentiality, especially when dealing with criminal offenses, but EDF will inform the whistleblower first that their name is to be disclosed, unless there is a legal requirement not to do so or the police advises not to do so.

In the event of submitting a complaint/report, the administrator of your personal data will be the Education for Democracy Foundation, based in Warsaw at ul. Nowolipie 9/11. Your personal data will be processed in order to consider the complaint/report. This processing is necessary to fulfill the legal obligation imposed on the administrator.

 TYPES OF CASES CONSIDERED

  • concerning sensitive issues, e.g. human rights violation, EDF ethical values violation, all matters concerning sexual harassment, discrimination, unequal treatment, mobbing, harassment, safety concerns. Concerns regarding sensitive issues are prioritized and addressed as soon as possible. Internal investigation is mandatory.The person raising the complaint will be informed about the initiation of the investigation and its conclusion.
  • concerning fraud and financial malpractice, e.g. fraud, corruption, mismanagement, procurement rules violation, money laundering, terrorism. Proceedings can take up to 30 calendar days to gather facts and proofs. Decision on measures to be taken (case closed or open investigation) will be communicated to the person raising the complaint.
  • regarding Programme matters, e.g. quality of services, materials, training delivered, publications. Proceedings can take up to 30 calendar days to gather facts and proofs. Decision on measures to be taken (case closed or open investigation) will be communicated to the person raising the complaint.
  • Other complaints relating to EDF internal rules and regulations. Proceedings can take up to 30 calendar days to gather facts and proofs. Decision on measures to be taken (case closed or open investigation) will be communicated to the person raising the complaint.

 

NEXT STEPS

Depending on the nature of the concern EDF may appoint a team of experts to investigate the complaint. Every member of such a team must sign a Declaration of no conflict of interest and a Declaration of confidentiality.

Disciplinary action will be taken against employees found to have committed irregularities and abuses. Other stakeholders in breach of this Policy’s provisions risk termination of any contracts and cooperation with the Foundation.

If the claim described in the complaint is not confirmed the person it refers to is cleared of suspicion.

Knowingly providing false information will result in disciplinary action. 

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