Whistleblower Policy

1. Purpose

UPMA is committed to maintaining high standards of integrity, accountability, and transparency. This Whistleblower Policy provides a framework for employees, volunteers, board members, and other stakeholders to report concerns regarding financial mismanagement, unethical behavior, legal violations, or other misconduct.

2. Reporting Violations

Any individual who observes or becomes aware of suspected fraudulent, illegal, or unethical conduct is encouraged to report their concerns promptly. Reports may be made:

Directly to a supervisor or department head
To the Executive Director or Board Chair
Through a confidential reporting mechanism (e.g., an anonymous hotline or email)

3. Confidentiality

All reports will be handled with discretion, and confidentiality will be maintained to the extent possible, consistent with the need to conduct a thorough investigation. Anonymous reports will also be accepted and investigated appropriately.

4. Protection Against Retaliation

UPMA strictly prohibits retaliation against any individual who, in good faith, reports suspected wrongdoing or participates in an investigation. Any act of retaliation should be reported immediately and will be subject to disciplinary action.

5. Investigation and Resolution

All reports will be promptly reviewed, and an impartial investigation will be conducted as necessary. If wrongdoing is found, corrective action, including disciplinary measures, will be taken. The organization will strive to keep the whistleblower informed of the outcome where appropriate.

6. Compliance and Oversight

The Board of Directors will oversee compliance with this policy. This policy will be reviewed annually to ensure its effectiveness and alignment with best practices.

7. Acknowledgment

Employees and stakeholders will be informed of this policy and required to acknowledge their understanding upon joining the organization.

Document Retention and Destruction Policy

1. Purpose

The purpose of this policy is to establish guidelines for the retention, storage, and proper destruction of UPMA’s documents to ensure compliance with legal and regulatory requirements, promote transparency, and maintain the integrity of UPMA’s records.

2. Scope

This policy applies to all UPMA employees, board members, volunteers, and any individuals responsible for creating, maintaining, or disposing of UPMA records, including electronic and paper documents.

3. Document Retention

UPMA shall retain documents for the periods specified below, unless otherwise required by law:
Corporate Records (Articles of Incorporation, Bylaws, Board Meeting Minutes, IRS Determination Letter) – Permanent
Financial Records (Audited Financial Statements, Tax Returns, Bank Statements, Grant Records) – 7 years
Legal Records (Contracts, Leases, Insurance Policies) – 7 years after expiration
Employee and Payroll Records – 7 years after termination
Donor and Contribution Records – 7 years
Program and Service Records – 5 years
Electronic Communications (Emails, Digital Correspondence) – 3 years, unless legally required to retain

4. Document Storage and Security

Documents, whether physical or electronic, must be stored securely to prevent unauthorized access, loss, or damage. Sensitive or confidential records must be stored in locked filing cabinets or secure digital storage systems with restricted access.

5. Document Destruction

Documents that have met their retention period shall be destroyed in a secure manner:
Paper Records: Shredding or incineration
Electronic Records: Permanent deletion and removal from all storage locations, including backups
Any documents subject to ongoing litigation, audits, or government investigations must not be destroyed until final resolution, even if the retention period has expired.

6. Compliance and Oversight

The Executive Director or an appointed officer is responsible for implementing this policy, ensuring compliance, and periodically reviewing record retention schedules. Employees and volunteers must follow this policy and report any concerns regarding non-compliance.

7. Policy Review and Amendments

This policy shall be reviewed at least every three years or as necessary to remain compliant with IRS regulations and legal requirements. Amendments must be approved by the Board of Directors.