Whistleblower Policy

Purpose

The purpose of this Whistleblower Policy is to:

• Encourage and enable employees, volunteers, beneficiaries, donors, and stakeholders to report any unethical behavior, misconduct, or wrongdoing in good faith.
• Establish a safe and confidential process for reporting concerns.
• Protect whistleblowers from retaliation, discrimination, or victimization.

AIM Foundation is committed to the highest standards of integrity, transparency, and ethical conduct in all its operations and activities.

Scope

This policy applies to:

• Employees, volunteers, interns, and consultants
• Board members and trustees
• Donors, partners, vendors, and beneficiaries
• Any other stakeholder associated with AIM Foundation

Reports may relate to:

• Financial irregularities or fraud
• Misuse of organizational funds or assets
• Corruption or bribery
• Harassment or abuse (including child abuse or exploitation)
• Discrimination or violation of human rights
• Violation of AIM Foundation policies, including Code of Conduct, Safeguarding Policy, etc.

Principles

• Confidentiality: All reports will be handled confidentially, and the identity of the whistleblower will be protected.
• Non-Retaliation: No individual will face retaliation for reporting a concern in good faith, even if it is later found to be unsubstantiated.
• Good Faith: Reports must be made honestly and based on reasonable grounds.

Reporting Channels

Whistleblowers can report concerns through any of the following confidential channels:

Anonymous Reporting: Reports may also be submitted anonymously. However, including contact details may help with investigation and resolution.

All complaints will be directed to the Whistleblower Committee or a designated Compliance Officer.

Investigation Process

1. Acknowledgment: Complaints will be acknowledged within 5 working days.
2. Preliminary Review: The Whistleblower Committee or designated officer will conduct a preliminary review to assess validity.
3. Investigation: A full investigation will be initiated if the complaint warrants further inquiry. This may include interviews, document review, and gathering of evidence.
4. Outcome: Based on findings, necessary action will be taken, which may include disciplinary action, legal reporting, or corrective measures.
5. Closure: The whistleblower (if identified) will be informed of the resolution status, subject to legal and confidentiality considerations.

Protection Against Retaliation

AIM Foundation strictly prohibits retaliation, harassment, or discrimination against any person who reports a concern in good faith. Any retaliatory action will be treated as a serious violation of this policy and may lead to disciplinary action, including termination or legal proceedings.

False Allegations

If a complaint is found to be knowingly false or malicious, AIM Foundation reserves the right to take appropriate disciplinary action against the individual making the false claim.

Records and Documentation

All reports, investigations, and outcomes will be documented and securely stored. Periodic summaries may be shared with the Board of Trustees while maintaining confidentiality.

Review of Policy

This policy will be reviewed annually and revised as necessary to comply with best practices, evolving legal standards, and organizational needs.