Distribute Aid requires directors, coordinators, and other volunteers to observe high standards of organisational and personal ethics in the conduct of their duties and responsibilities. As representatives of Distribute Aid, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws, regulations, and internal ethical policies. Doing this helps us be as effective as possible at pursuing our mission!
This Whistleblower Policy is intended to encourage and enable individuals to raise serious concerns without retribution so that Distribute Aid can address and correct inappropriate conduct and actions. It is the responsibility of all board members, directors, coordinators, and volunteers to report concerns about violations of Distribute Aid’s Code of Conduct or suspected violations of law or regulations that govern Distribute Aid’s operations. Such violations could include using racist, sexist, ableist, or otherwise derogatory and discriminatory language, or graver violations such as putting the safety of people on the move at risk by willfully exposing locations or publicising photographs with sensitive information.
It is the policy of Distribute Aid that a Whistleblower shall receive no retaliation or retribution for a report that was provided in good faith. Anyone who retaliates against the Whistleblower (who reported an event in good faith) at any point in the process described below will be subject to discipline.
The following outlines the procedure for anyone to raise concerns about the conduct of any member of Distribute Aid or practice carried out by the organisation.
Internal Reporting Procedure for Individuals with a Concern is as Such:
- The Whistleblower begins the process when they have good faith, reasonable grounds for believing that a violation has occurred.
- If the person is not acting in good faith and offers unsubstantiated allegations made maliciously or knowingly to be false, this can be viewed as a disciplinary offence.
- Assuming they are acting in good faith, the Whistleblower should first decide if they wish for their report to be anonymous or not.
- If they do not wish to report anonymously, they may use any written medium (email, document, etc.) to file the report with the proper individual, per step 3.
- If they do wish to report anonymously, they should create an account on ProtonMail ¹ with an anonymous address, such as a random sequence of numerals. See Appendix B of this document for instructions on how to set up a Proton Mail Account to File a Report ².
- If the Whistleblower is uncomfortable or otherwise reluctant to report to the relevant director (for example, if said director is the source of the concern), then the Whistleblower may report the event to the next highest level of management, which is the Executive Director (see Appendix A of this document for contact information). If the Whistleblower is uncomfortable or otherwise reluctant to report to the relevant director and the Executive Director, then the Whistleblower may report the event to an appropriate board member (see Appendix A of this document for contact information). For financial concerns the Whistleblower may contact the Auditor (see Appendix A of this document for contact information).
- It is the responsibility of the person who receives a report to promptly investigate and/or resolve the issue.
- Throughout this investigation and the entire process, the identity of the Whistleblower, if known, shall remain confidential to all persons directly involved in applying this policy, unless the issue requires investigation by law enforcement, in which case members of the organisation may be required to disclose this information to law enforcement.
- The investigating individual shall send a report to the Whistleblower within seven days of the initial report, regarding the investigation, disposition, or resolution of the issue. This report must be in writing.
- If the initial report was not filed anonymously, then the investigative report may be issued by email or print to the Whistleblower.
- If the initial report was filed anonymously, then the investigative report must be sent via ProtonMail to the same address that the initial report came from.
- If the Whistleblower is not satisfied with the report from the internal investigator, then they have the right to report the event to the next highest level of authority within the organisation for another 7-day investigation or to the appropriate legal or investigative agency. If the Whistleblower chooses to report internally, then the process returns to step 2.
- For example, if someone is unsatisfied with the Operations Leads’ resolution, they could file a second report with the Executive Director.
Reporting to Authorities
At any point during the process, a Whistleblower may choose to file a report with the appropriate legal or investigative agency, outside of Distribute Aid. Crimes against persons or property, such as assault, burglary, etc., should immediately be reported to local law enforcement personnel. Sweden does not have a dedicated agency for overseeing non-profit organisations.
The following agencies may be helpful depending on the nature of the issue:
- Swedish Tax Agency, skatteverket.se, +46 771 567 567
- Swedish Consumer Agency, report form, firstname.lastname@example.org
- Swedish Police, report form, +46 77 114 14 00.
Appendix A: Contact Information for Relevant Parties
Appendix B: Instructions for Setting Up Proton Mail Account to File a Report
- Go to protonmail.com.
- Select “Sign Up” in the top right.
- Select the “Free” option and then click “Select Free Account.”
- Select a username that is not personally identifiable, like a meaningless string of numerals. Select a password, and record it somewhere so that you can access your account later.
- You may choose to add a recovery method. If you do not do this and lose your password, then you will be unable to log into your account later to check on the status of your report and receive your 7 day investigative report. If you do choose to add a recovery method, this information will not be visible to Distribute Aid at any point during the reporting process.
- If you do not wish to add a recovery method, click “Skip”.
- Select the free plan once again.
- Verify that you are a human via Captcha or one of the other options.
- You should be redirected to an email inbox. You can now compose a message.
Note: Take care to record your login details for ProtonMail so that you can log back in and see when a response comes in, since DA will not be able to see or reset your password.