ADDRESSING THE REPORTING OF IMPROPRIETIES, FRAUDULENT OR DISHONEST CONDUCT

It is the policy of the Board of Directors to safeguard and protect all of the nonprofit’s resources. The Board is primarily responsible for safeguarding the organization’s resources by establishing and maintaining sound internal controls designated to deter and detect potential misuse of resources, by taking action to minimize financial loss when misuse occurs, by correcting abuse, and by delegating authority as appropriate. Members of the Board and the officers and staff of Westmoreland Land Trust are encouraged and required to report any improprieties of this nature that they may observe or have reason to suspect.

The Board of Directors will investigate any reported impropriety, fraudulent or dishonest use or misuse of Westmoreland Land Trust’s resources or property. Anyone found to have engaged in an impropriety or fraudulent activity is subject to disciplinary action of the Board up to and including termination or dismissal, and civil or criminal prosecution where warranted.

Reports of possible fraudulent of dishonest conduct (including but not limited to financial improprieties or misuse of the organization’s resources) are to be made to the Board Chair unless the person finds it difficult to report his or her findings to that person in which case the person can report to the Vice Chair of the Board. Every effort will be made to provide anonymity to those reporting improprieties unless Westmoreland Land Trust is required by applicable law to disclose the source of this information.

Examples might include:

• Forgery or alteration of documents
• Pursuit of a benefit or advantage in violation of the organization’s conflict of interest policy
• Misappropriation or misuse of organization’s resources, such as funds, supplies, other assets
• Authorizing or receiving compensation for goods not received, services not performed, or hours not worked
• Fraudulent financial reporting

Criteria used to determine whether certain activities or behavior constitute misuse of resources include state and federal laws and the organization’s adopted policies.

Adopted by the Westmoreland Land Trust Board of Directors on September 24, 2008.

The mission of the Westmoreland Land Trust is to conserve and steward lands and waters of Westmoreland County that harbor ecological, scenic or recreational qualities to offer a healthier and more sustainable future for all.