Policy on Suspected Misconduct and Whistleblower Protection

I. Purpose

Hope Community Church (HCC) is committed to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, this policy aims to provide an avenue for employees and any other person to raise concerns about suspected misconduct and to provide reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith.

II. Definition of Terms

For the purpose of this policy, the definition of “Misconduct” includes but is not limited to:

  • acts which are inconsistent with church policy,

  • theft or other misappropriation of church assets,

  • misstatements or other irregularities in church records,

  • incorrect financial reporting,

  • misuse of church resources,

  • illegal activities,

  • immoral or unbiblical activities,

  • forgery or alteration of documents, and

  • any form of fraud.

Unless otherwise specified, the term “Staff” refers to compensated individuals, full-time and part-time, employees and independent contractors, including those receiving a stipend. “Volunteer(s)” refers to those providing a service without compensation. “Elder Board” refers to Members of the Elder Board that provide a service without compensation. “Ethics and Compliance Committee” refers to members of the committee that provide a service without compensation.

III. Procedure

Reporting
Staff or any other person who has a concern relating to suspected Misconduct may make a report. For purposes of this policy, persons who make a report are referred to as “Reporters”. HCC wants to hear of any and all possible Misconduct.

  • To ensure a confidential forum for reporting possible Misconduct, HCC has established a submissions portal on its website, https://hopecommunity.net/whistleblower to enable anyone to raise a concern, complaint, or issue to the Ethics & Compliance Committee.

  • While reported Misconduct may be submitted anonymously, the reporting person should understand that anonymity might impede HCC’s ability to conduct a complete investigation.

  • Suspected Misconduct made known via other channels such as direct email, phone calls, or personal conversations will be forwarded directly to the Ethics & Compliance Committee where they will be formally documented and addressed.

  • Should members of the Ethics & Compliance Committee be involved (directly or indirectly) in the reported Misconduct, such Misconduct shall be reported to any member(s) of the Elder Board.

Investigating the Concern
Following the receipt of any complaints submitted, the Ethics & Compliance Committee shall investigate each matter so reported and recommend corrective and disciplinary actions where appropriate.

The Ethics & Compliance Committee may enlist the Elder Board, employees of the ministry and/or outside legal, accounting, or other advisors/authorities, as appropriate, to conduct an investigation of any form of Misconduct. In conducting any investigation, the Ethics & Compliance Committee shall use reasonable efforts to protect the confidentiality and anonymity of the Reporter to the extent possible while conducting a thorough investigation. Should members of the Ethics and Compliance Committee be involved in the issue (directly or indirectly), the Elder Board Chairperson shall appoint a member of the Board to coordinate investigation activities.

Further Information
The amount of contact between the Reporter and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the Reporter.

Response to Reporter
The Reporter will be given the opportunity to receive follow-up on their concern within two weeks:

  • Acknowledging that the concern was received;

  • Offering pastoral care, as appropriate;

  • Indicating how the matter will be dealt with;

  • Giving an estimate of the time that it will take for a final response;

  • Informing the Reporter whether initial inquiries have been made; and

  • Informing the Reporter whether further investigations will follow, and if not, why.

Information
Subject to any applicable legal constraints, the Reporter will receive information about the outcome of any investigations.

Document Retention
The Ethics and Compliance Committee shall retain as a part of the records of the Committee, any such complaints, concerns, and relevant documents or materials, for a period of at least seven years.

IV. SAFEGUARDS

No Retaliation
No Staff or other person who in good faith reports Misconduct shall suffer harassment, retaliation, or adverse employment consequences. Any Staff member who retaliates against someone who has reported Misconduct in good faith is subject to discipline, up to and including termination of employment. This policy is intended to encourage and enable Staff and others to raise concerns within the church prior to seeking resolution outside the church.

Additionally, no Staff shall be adversely affected because they refuse to carry out a directive which, in fact, constitutes Misconduct, fraud, or is a violation of state or federal law.

Confidentiality
Misconduct or suspected Misconduct may be submitted on a confidential basis by the Reporter or may be submitted anonymously. Reports of Misconduct or suspected Misconduct will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Reasonable efforts will be made to protect the Reporter’s identity.

Anonymous Allegations
Staff are encouraged to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, but consideration will be given to:

  • The seriousness of the issue raised;

  • The credibility of the concern; and

  • The likelihood of confirming the allegation from attributable sources.

Acting in Good Faith
Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed could indicate Misconduct. Any allegations which prove to have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.

One way to report misconduct is to complete the form below. Hope Community's "Ethics and Compliance Committee" (ECC) will review each submission. The ECC members are Katy Schmeissing (Elder), Jon Lake (Hope Staff), and Shirley Mathai (Congregant)

HCC reserves the right to modify or amend this policy at any time as it may deem necessary.
Date Written: 11/4/2022
Date Reviewed/Revised: 11/15/2022
Date of Approvals: 2/21/2023