General

The Natomas Basin Conservancy (Conservancy) expects its directors, officers, employees, and other representatives to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Conservancy, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all directors, officers, and employees to report Wrongful Conduct in accordance with this Whistleblower Policy.

Wrongful Conduct

“Wrongful Conduct” means: a policy, practice or activity in violation of or noncompliance with applicable state and federal law or regulation or the use of Conservancy property, resources, or authority for personal gain or other non-organization-related purpose except as provided under Conservancy policy.

Authority of Audit Committee

The Audit Committee shall have full authority to investigate concerns raised in accordance with this policy and may retain outside legal counsel, accountants, private investigators, or any other resource that the Committee reasonably believes is necessary to conduct a full and complete investigation of the allegations.

No Retaliation

No director, officer, or employee who reasonably believes that a policy, practice, or activity is in violation of the law and reports Wrongful Conduct will suffer retaliation for making the report. Retaliation includes harassment or adverse employment actions, such as unwarranted discipline or termination. Any director, officer, or employee who retaliates against anyone who has reported Wrongful Conduct in good faith is subject to discipline up to and including termination of employment or removal from the board of directors, as applicable. This policy is intended to encourage and enable employees and others to raise serious concerns within the Conservancy prior to seeking resolution outside the Conservancy.

The Conservancy will not retaliate against director, officer or employee who, with reasonable cause, discloses or threatens to disclose any violation of a law or regulation to any government or law enforcement agency.

The Conservancy will not retaliate against any director, officer, or employee who refuses to participate in any conduct that would result in a violation of state or federal law or regulation.

Reporting Wrongful Conduct

The Conservancy encourages its directors, officers, and employees to share their questions, concerns, suggestions, or complaints with someone who can address them properly. Any director, officer, or employee may report Wrongful Conduct to the Executive Director or the president of the board of directors. If the Wrongful Conduct implicates one or both of the Executive Director or the president of the board of directors, or if the reporting individual is not comfortable speaking with or not satisfied with the response of the foregoing individuals, the issue may be reported to any member of the Audit Committee or any member of the board of directors. The Executive Director, president of the board of directors, and all members of the board of directors to whom a report of Wrongful Conduct is made are required to immediately advise the full board of directors of such report of Wrongful Conduct.

Acting in Good Faith

Anyone filing a complaint of Wrongful Conduct must be acting in good faith and have reasonable cause for believing the information disclosed indicates Wrongful Conduct. The determination of good faith and reasonable cause shall be made in the sole discretion of the Audit Committee. Any allegations that prove to be unsubstantiated and made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Reports of Wrongful Conduct or suspected Wrongful Conduct will be kept confidential on a “need-to-know” basis, consistent with the need to conduct an adequate investigation.
Handling of Reported Wrongful Conduct

A representative of the board of directors will notify the reporter and acknowledge receipt of the reported Wrongful Conduct or suspected Wrongful Conduct within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.