SASF WhistleBlower Policy

Purpose

SAS Foundation is committed to maintaining the highest standards of integrity, accountability, and transparency in all aspects of its operations. This Whistleblower Policy aims to:

• Encourage employees, volunteers, partners, and stakeholders to report unethical, improper, or illegal conduct.
• Protect whistleblowers from retaliation or victimization.
• Ensure reported concerns are handled confidentially and appropriately investigated.

Scope

This policy applies to all:

• Trustees and board members
• Employees and consultants
• Interns and volunteers
• Beneficiaries and partner organizations
• Vendors and other stakeholders

What Can Be Reported

You may report concerns related to:

• Fraud, corruption, or financial misconduct
• Abuse of authority or misuse of resources
• Discrimination or harassment
• Violation of laws, regulations, or policies
• Environmental or human rights violations
• Conflicts of interest
• Any conduct that poses a risk to the integrity of SAS Foundation

Reporting Channels

Reports can be submitted via:

• Email: contact@sas-foundation.in
• Postal Mail: Marked ‘Confidential – Whistleblower’ and addressed to: The Managing Trustee, SAS Foundation, RZ-54/5A, Rajnagar Part 2, Palam Colony, New Delhi 110077.
• In-person meeting: By scheduling a confidential discussion with the Secretary or President.

Anonymous complaints will also be accepted, though providing contact details will help in conducting a thorough investigation.

Confidentiality

All reports and the identity of whistleblowers will be kept strictly confidential to the extent possible. Disclosure may be required only when:

• Required by law
• Necessary for the investigation
• Consent has been obtained

Protection from Retaliation

SAS Foundation will not tolerate retaliation or harassment against any whistleblower who raises concerns in good faith. Retaliation may lead to disciplinary action, including termination or legal action.

Investigation Procedure

• Upon receiving a complaint, the Secretary (or a designated Ethics Officer) will acknowledge receipt within 5 working days.
• A preliminary review will be conducted within 10 working days.
• If the matter warrants further investigation, a Review Committee (minimum of two trustees and one external advisor, if needed) will be constituted.
• Findings will be documented, and appropriate action will be taken within 30 working days, extendable based on complexity.
• The whistleblower (if identified) will be informed of the outcome, where appropriate.

False Allegations

If a report is found to be intentionally false or malicious, disciplinary action may be taken against the complainant.

Recordkeeping and Reporting

All whistleblower reports and investigations will be logged and retained securely. A summary of cases (without revealing identities) may be presented to the Board annually for transparency and oversight.

Review and Amendment

This policy will be reviewed annually by the Board of Trustees. Amendments may be made as deemed necessary to ensure effectiveness and compliance with legal or regulatory changes.