Whistleblower Policy

ARTICLE I: PURPOSE

The Open Accounts Receivable Collective Foundation (the “Foundation”) is committed to operating with integrity, transparency, and accountability. This Whistleblower Policy encourages directors, officers, employees, contractors, volunteers, and community participants to report, in good faith, suspected violations of law or Foundation policy, and protects those who make such reports from retaliation.

ARTICLE II: SCOPE

This policy applies to all directors, officers, employees, contractors, and volunteers of the Foundation, and to all community participants, meaning individual members of the Foundation’s recognition membership program, organizations participating in the Foundation’s Mission Supporter program, and any other person participating in a Foundation community space or program. It covers reports of suspected violations including, but not limited to:

• Violations of federal, state, or local law

• Financial misconduct, fraud, or misappropriation of Foundation assets

• Violations of the Foundation’s governance policies, including the Conflicts of Interest Policy

• Conduct that threatens the Foundation’s charitable mission or tax-exempt status

• Other ethical violations or conduct contrary to the Foundation’s values.

ARTICLE III: REPORTING PROCEDURES

Section 3.1. How to Report

Any person covered by this policy who reasonably believes that a violation has occurred or is occurring is encouraged to report the concern as promptly as possible using one of the following methods:

Direct Report: Submit a report in writing to the Chair of the Board of Directors or the Chair of the Finance and Audit Committee (if established).

Anonymous Report: Submit an anonymous written report to the Chair of the Board or Finance and Audit Committee. Anonymous reports may be submitted through channels published by the Foundation, including postal mail to the Foundation’s registered office and an electronic reporting form. Anonymous reports will be investigated to the extent possible given the information provided.

Reports Involving the Chair: If a concern involves the Chair of the Board, the report may be made to the Vice Chair or, if no Vice Chair is serving, to any other director.

Section 3.2. What to Include

Reports should include: a description of the conduct giving rise to concern; the names of the persons involved, if known; relevant dates; and any supporting documentation. Reports need not be exhaustive to trigger an investigation; a good-faith concern is sufficient.

Section 3.3. Reporting to Outside Authorities

Nothing in this policy prevents any person from reporting suspected violations of law to appropriate governmental authorities, including the IRS, state attorneys general, or law enforcement agencies. Persons who in good faith report suspected violations to such authorities are protected under this policy.

ARTICLE IV: CONFIDENTIALITY

The Foundation will make reasonable efforts to keep the identity of any person who reports a concern confidential, consistent with the need to conduct a thorough investigation. Confidentiality cannot be guaranteed in all circumstances, including where disclosure is required by law or where disclosure is necessary to investigate or remediate the reported concern. The Foundation will not disclose the identity of a reporting person more than is necessary under the circumstances.

ARTICLE V: NO RETALIATION

The Foundation prohibits retaliation against any person covered by this policy who, in good faith, reports a suspected violation under this policy or who participates in an investigation. Prohibited retaliation includes: termination of employment or engagement; demotion; suspension; harassment; threats; suspension or revocation of membership or of participation in any Foundation program; removal from a Foundation community platform; or any other adverse action. Any person who retaliates against a reporting person will be subject to disciplinary action, up to and including termination.

No report made in good faith under this policy will be treated as a violation of the community standards adopted under the Community Programs and Standards Policy, or as conduct inconsistent with the Foundation’s charitable purposes, and no such report will be a ground for action under Article VII of that policy.

Reports made in bad faith or with knowledge that the reported information is false are not protected by this policy and may result in disciplinary action.

ARTICLE VI: INVESTIGATION PROCEDURES

Upon receipt of a report, the Chair of the Board or Finance and Audit Committee Chair will determine the appropriate response. The recipient will acknowledge receipt of a non-anonymous report within ten (10) business days. Where the Chair is implicated in a report, the Vice Chair, or the director who received the report if no Vice Chair is serving, will assume the Chair’s functions under this Article for that report. Investigations will be conducted by a designated person or committee of disinterested directors. Any person who is the subject of a report will not participate in the investigation of that report.

The investigation will be conducted promptly and thoroughly. The Foundation may retain outside counsel or other experts to assist with complex investigations. The results of the investigation will be reported to the Board of Directors.

The Foundation will take appropriate corrective action based on the findings of the investigation. If a crime is suspected, the Foundation may report the matter to appropriate law enforcement authorities.

ARTICLE VII: POLICY ADMINISTRATION AND REVIEW

The Chair of the Board of Directors is responsible for administering this policy; the Vice Chair will administer this policy with respect to any report in which the Chair is implicated. All directors, officers, employees, contractors, and volunteers will be informed of this policy upon joining the Foundation and annually thereafter. Community participants will be informed of this policy through the Community Participation Terms agreed to upon admission, and the Foundation will publish the policy and its anonymous reporting channel on its website. This policy may be updated by the Board of Directors and will be reviewed at least annually. Substantive changes will be announced through the Foundation’s official channels and reflected in the dated version of this policy. The current version of this policy supersedes any prior version.