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Our Third-Party Whistleblower Policy

While Animal Charity Evaluators (ACE) does not operate as a watchdog organization, we are committed to encouraging the animal advocacy movement to protect and support workers and volunteers. In line with this, ACE provides an avenue for current or former employees, board members, volunteers, contractors, and other stakeholders, herein referred to as “Claimants,” to raise concerns they may have about the subjects covered by this policy. Claimants may have information about any organization that (i) we interact with through our charity evaluations or grantmaking programs or (ii) is otherwise involved in the animal advocacy movement.

Concerns raised to us may affect whether we consider an organization to be eligible to participate in current or future charity evaluations or Movement Grants. In most cases where we decide to take action, this will consist of sharing relevant non-confidential information with the leadership of the organization in question and encouraging them to take appropriate action. Given that we have neither the capacity nor the expertise to verify reports by carrying out a formal investigation, we will typically take more serious action only if we have considerable evidence of extreme incidents having taken place.

Please note that anonymous complaints will be thoroughly reviewed, but it may be difficult for us to take action unless we are able to verify the concern with further collaboration from the anonymous source.

Purpose of Policy

This policy covers instances where a Claimant of the organization in question has evidence of activity (“Reportable Activity”) by any current or former employees, board members, volunteers, contractors, and other stakeholders, associated with that organization, that to their knowledge constitutes:

  • Any form(s) of harassment or discrimination
  • Accounting, auditing, or other financial reporting fraud or misrepresentation, including misuse of public funds or public assets, forgery of documents, authorizing or accepting compensation for services not performed
  • Violations of laws that could result in fines or civil damages payable by the organization, or that could otherwise significantly harm the organization’s reputation or public image;
  • Inappropriate occurrences at a professional event
  • An act or omission that creates a substantial and specific danger to the health, safety, or wellbeing of employees, members, and volunteers
  • Abuse of power or authority
  • Activities not in line with the mission of the organization
  • Concealment of any of the above

Above all, ACE will prioritize protecting a Claimant who brings forward a Reportable Activity from being identified or retaliated against by the organization under complaint.

Definitions

Individual Characteristics

These refer to the unique characteristics of an individual, including an individual’s race, color, religion, ancestry, marital status, family status, sex, sexual orientation, age, political belief, physical or mental disability, body size, gender or gender expression, pregnancy or parental status, national origin, citizenship, ancestry, caste, veteran status, genetic information, and other such characteristics.

Harassment

For the purposes of this policy, Harassment includes bullying, intimidation, and nonsexual harassment (whether physical, verbal, or nonverbal) that has the effect of upsetting, demeaning, humiliating, intimidating, or threatening an individual. Harassment usually affects an individual’s ability to perform their job as best as possible. It can also affect an individual’s dignity and self-respect. Harassment can occur between coworkers and between leadership and non-leadership team members. Sexual harassment is defined separately below.

Some examples of Harassment include:

  • Aggression or yelling
  • Insulting or derogatory comments that may or may not relate to a person’s Individual Characteristics
  • Physical abuse or threats of abuse
  • Verbal or written threats
  • Humiliation, such as subjecting someone to unwelcome jokes or ridicule
  • Displaying offensive material in public or private channels
  • Offensive jokes or comments about a person’s Individual Characteristics
  • Epithets, slurs, or negative stereotyping
  • Threats of firing or demotion
  • Regularly excluding an individual from social events, including online social gatherings or work-related meetings
  • Removing job responsibilities without reasonable justification

Sexual Harassment

Sexual Harassment, a form of Harassment, includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical harassment of a sexual nature in the Workplace. Sexual Harassment does not always have to be specifically about sexual behavior or directed at a specific individual. For example, negative comments about women as a group may be a form of Sexual Harassment. Sexual Harassment also includes gender-related Harassment, which is defined as negative treatment of, or hostility toward, an individual on the basis of gender, gender expression, or family status.

Some examples of Sexual Harassment include:

  • Requests for sexual favors
  • Verbal harassment of a sexual nature, including jokes or comments referring to sexual acts or sexual orientation
  • Unwelcome sexual advances
  • Discussing sexual relations/stories/fantasies
  • Physical acts of sexual assault
  • Unwanted touching or physical contact
  • Making conditions of employment or advancement dependent on sexual favors, either explicitly or implicitly
  • Exposing oneself or performing sexual acts on oneself
  • Pressuring someone into sexual engagement
  • Unwanted sexually explicit photos, emails, or text messages

Discrimination

Discrimination refers to differential treatment of, exclusion of, or hostility toward an individual on the basis of their Individual Characteristics.

Workplace

The Workplace refers to any physical or virtual space where your organization’s work occurs. This includes, but is certainly not limited to, any place where you gather for work-related events, social calls, and optional meetings or staff retreats. It also includes social media and other online platforms where your organization’s team members interact. In other words, the Workplace is any space where you are present due to your work with the organization, even outside of work hours. We recognize that Harassment may occur during a holiday and at locations away from work. If you were subject to such behavior during the weekend, for example, or at a social function that is unrelated to your employment or role as a volunteer, this would not preclude the individual from culpability.

Process For Bringing Forward a Concern

A Claimant may contact ACE’s Programs Director, Elisabeth Ormandy, at elisabeth.ormandy@animalcharityevaluators.org or use our Claimant Contact Form. The Programs Director is the only one with access to the form responses. The Claimant may choose to provide a written statement detailing the Reportable Activity or have a call with any member of ACE’s staff. In the case of a call, the ACE staff member will request to take notes to record the details of the Reportable Activity.

Confidentiality

Protecting the confidentiality of the Claimant is our highest priority when dealing with whistleblower claims. ACE treats all reports made under this policy as confidential to the fullest extent possible. Throughout the process, the Claimant will be consulted on how we handle the information provided. We will discuss this on an individual basis with each claimant that reaches out to us.

Some examples of accommodations we can make:

  • In a call to provide details of the Reportable Activity, the Claimant may opt out of notes being taken.
  • Any notes taken during a call with the Claimant will be sent to the Claimant for editing and approval prior to any sharing with other staff members at ACE.
  • The Claimant may request that only the ACE staff in direct contact with them (or a limited subset of staff, e.g., the Charity Evaluations Committee) can have access to the notes or written statement.
  • In most cases, we will require permission from the Claimant before taking any action that might affect the Claimant’s ability to remain anonymous, e.g., discussing reports being made against an organization in our reviews. However, please be aware that while we will do our utmost to protect the Claimant’s anonymity and the confidentiality of their report, this cannot be fully guaranteed. For example, if we learn of illegal activity at the organization in question, or of the potential for a violent crime to be committed, we may be legally obliged to report this to the relevant authorities.

Note: If a Claimant declines written documentation and/or chooses to limit the number of ACE staff who can access the documentation, this may limit ACE’s ability to take action to address the issue. Similarly, the more relevant non-confidential information we are able to share with the leadership of the organization in question, the more likely we are to be able to encourage positive remedial action.

Storage of Information

Call notes: Initially, call notes will be stored on the Google Drive of the ACE staff member who recorded them until permission is given by the Claimant to share with other staff. The notes will then be moved to the relevant folder, and access will be given to any staff member(s) as approved by the Claimant.

Emails: Emails will not be forwarded or saved anywhere where they could be accessed by other ACE staff until permission is given by the Claimant to share with other ACE staff members. The notes will then be moved to the relevant folder, and access given to relevant staff member(s) as approved by the Claimant.

Providing Details on The Subject Matter of The Complaint

The Claimant should give as much information as possible on the matter of the complaint and procure/keep as much documentation as possible. Upon receiving a completed form in writing or via web submission and/or holding a call with an ACE staff member, action taken by ACE will depend on the nature of the Reportable Activity. Complaints will be handled in one of the following ways:

For organizations that are currently recommended as either a Top or Standout Charity:
We will review the information reported in the complaint as part of the next evaluation cycle, and we may factor that into any future recommendation decisions. Where appropriate, we will share any relevant non-confidential information with the leadership of the organization in question to understand their perception of the incident, what action they have taken to address it, and any further action they plan to take. If the complaint is serious enough (i.e., extreme), and we believe we have sufficient evidence to do so, we may take more action, e.g., by rescinding our recommendation of the organization. If permitted by the Claimant, we may include details of the Reportable Activity in our reviews of the organization.

For organizations that are currently undergoing evaluation:
We will review the information reported in the complaint as part of the evaluation cycle, and we may factor that into our recommendation decision. Where appropriate, we will share any relevant non-confidential information with the leadership of the organization in question to understand their perception of the incident, what action they have taken to address it, and any further action they plan to take. If the complaint is serious enough (i.e., extreme), and we believe we have sufficient evidence to do so, we may take more action, e.g., by removing the organization from our evaluations process. If permitted by the Claimant, we may include details of the Reportable Activity in our reviews of the organization. We may also take steps to ensure that a charity cannot be considered as eligible for charity evaluations or Movement Grants for at least 2 years.

For organizations or individuals that are being (or have previously been) considered for a Movement Grant:
We will review the information reported in the complaint as part of any current or future applications for funding through the Movement Grants program, and we may factor that into any future decisions. Where appropriate, we will share any relevant non-confidential information with the leadership of the organization in question to understand their perception of the incident, what action they have taken to address it, and any further action they plan to take. If the complaint is serious enough (i.e., extreme), and we believe we have sufficient evidence to do so, we may also request that unused grant funds be returned to us.

For organizations or individuals that do not fall into the categories above:
We will review the information reported in the complaint. The Programs Director will be responsible for ensuring that this information is considered in any future evaluations or grantmaking involving the organization in question. If the complaint is serious enough (i.e., extreme), and we believe we have sufficient evidence to do so, we may take steps to ensure that a charity cannot be considered for recommendation or Movement Grants for at least two years.

ACE does not have the expertise or capacity to investigate other organizations, and we are not a watchdog organization. However, as noted above, we may reach out to an organization (with permission from a Claimant) to assess how leadership responds to claims and whether there are policies and procedures in place to address any concerns that arise. Unless we are permitted by the Claimant to take this step, we may be unable to proceed as per the Claimant’s expectations or hopes, as denying the organization’s leadership the opportunity to respond could be deemed a lack of due process. However, if an organization refuses to acknowledge our concerns, we may construe that accordingly.