Whistleblower Policy and Procedure

Policy Statement

It is the policy of the International Center for Transitional Justice, Inc. (the “ICTJ” or “Organization”) to ensure the responsible stewardship of ICTJ resources. In order to further the efficient, effective, and economic use of ICTJ’s assets and resources and to ensure the effective and efficient operation of the Organization in compliance with applicable laws, regulations and policies, ICTJ must memorialize its position on fraud, waste, abuse, and mismanagement and the responsibilities of individuals that are provided with or have access to ICTJ’s resources. Therefore, the ICTJ has established a whistleblower policy (the “Policy”) which enables the Organization’s employees and consultants (“Reporting Person” or, collectively, “Reporting Persons”) to report to the Organization allegations of known or suspected Improper Activities (as defined below).

“Improper Activities” generally include, but are not limited to:

(i) questionable accounting, internal accounting controls or auditing matters; (ii) public disclosures made by the Organization that may not be complete or accurate; (iii) serious violations of the Organization’s Bylaws, the Employee Handbook, or any of the ICTJ’s internal policies; (iv) violations of applicable Federal or state laws or regulations or other laws applicable to the Organization; (v) any other fraud against the Organization; (vi) forgery or alteration of documents; (vii) misappropriation or misuse of Organization resources, such as funds or other assets; (viii) authorizing the receipt of compensation for goods not received or services not performed; or (ix) any other activity by an employee or consultant that is in violation of any applicable law or regulation (e.g. state, federal, national, municipal, etc.), or constitutes malfeasance, bribery, misuse of Organization property, or willful omission to perform the employee’s duties, or failure to exercise due diligence in the conduct of ICTJ’s operations resulting in substantial harm to the Organization, or involves gross misconduct.

The purpose of this Policy is twofold. First, it is to facilitate the reporting of “Improper Activities.” To that end, the ICTJ has established several reporting procedures to enable the communication of allegations of “Improper Activities,” which are detailed below. Secondly, to encourage Reporting Persons to come forward with credible information on illegal practices or violations of adopted policies, it is also ICTJ’s policy to protect Reporting Persons from retaliation.

This Policy also applies internationally, wherever the ICTJ has offices or operations. Employees and consultants resident and employed in the ICTJ's international offices abroad and outside of the United States are also required to comply with this Policy, as well as federal, state or local laws, regulations or other laws applicable to the Organization in that specific host country.

Policy Procedures

  1. Non-anonymous reporting procedures:

If a Reporting Person reasonably believes that any of the Organization’s employees or others acting on behalf of the Organization have engaged in an Improper Activity, the Reporting Person should first address his or her concerns with their immediate supervisor verbally or in writing. If the immediate supervisor is implicated in the allegations, the Reporting Person should proceed to “Anonymous reporting procedures” below. The immediate supervisor should then relay the allegations to the Human Resources Manager, or, should the Human Resources Manager be implicated in the complaint, to the Board Finance Committee Chair The Human Resources Manager, together with the supervisor of the Reporting Person, will memorialize the allegations in the attached “Allegations Report.” All information relative to allegations should be documented in an Allegation Report. The information must be recorded by  the Human Resources Manager, in collaboration with the Reporting Person’s direct supervisor.

For internal office tracking purposes, all allegations will also be recorded on an Allegation Report Control Log. Allegation Reports will be retained securely by the Human Resources Manager for a period of five years. A control number will be placed on each Allegation Report which is the principal tracking mechanism for allegations.

The Human Resources Manager will then apprise the Board Finance Committee Chair or, should the Board Finance Committee Chair be implicated in the complaint, the ICTJ’s Board of Director’s Chair, who will then decide that one of the following three (2) actions will be taken:

  • Take no further action on the allegation(s) because insufficient information was provided by the complainant.
  • Refer the allegation(s) to an ICTJ staff member that has the authority and ability to implement corrective action because the matter is considered minor or administrative by the Human Resources Manager. Conduct an audit or investigation of the allegation(s).

Audits or investigations will be performed by an outside finance or accounting firm and a report will be written. The Board Finance Committee Chair, with consultation appropriate for the situation, will determine the distribution of the report.

2. Anonymous reporting procedures:

Reporting Persons wishing to remain anonymous can make allegations in one of two ways: via a phone hotline or on the internet.

Complaints submitted via the Hotline or the EthicsPoint website will be processed by the NAVEX Global system administrator through the ICTJ’s Finance Committee Chair, who will then follow the course of action prescribed in the “Non-anonymous reporting procedure.” Reporting Persons wishing to avoid making the complaint via the Hotline because the allegation targets the Human Resources should write anonymously to the Finance Committee Chair at whistleblower@ictj.org.

No employee who in good faith filed a complaint by any means envisioned by this policy; has reasonable grounds for believing the reported fact; and has provided ICTJ with a reasonable opportunity to investigate and correct the alleged unlawful activity, shall suffer harassment, retaliation or adverse employment consequence resulting therefrom.


Failure to follow this policy or any other approved ICTJ policies shall result in disciplinary action, including termination of employment.