Whistleblower Protection Policy

Article 1: Introduction

1.1 Purpose

The Bitcoin District Initiative (hereinafter “the Corporation”) is committed to lawful, ethical, and transparent conduct in all its operations. This Whistleblower Protection Policy encourages directors, officers, employees, volunteers, and other stakeholders to report suspected wrongdoing, ensures compliance with applicable laws—including the District of Columbia Nonprofit Corporation Act (D.C. Code § 29-401 et seq.)—and protects individuals from retaliation. It affirms the Corporation’s commitment to a culture of accountability and integrity in support of its mission to advance Bitcoin education and personal sovereignty.

1.2 Scope

This policy applies to all individuals associated with the Corporation, including board members, officers, staff, volunteers, and contractors. Reportable concerns include:

• Financial misconduct, fraud, or mismanagement of funds.
• Violations of the Corporation’s policies or applicable federal, state, or local laws.
• Unethical behavior, conflicts of interest, or abuse of authority.
• Discrimination, harassment, or violations of employment laws.
• Misuse of organizational resources or donor-restricted funds.
• Conduct that jeopardizes the Corporation’s 501(c)(3) status.

Article 2: Reporting Procedures

2.1 Duty to Report

All Covered Persons (directors, officers, employees, and volunteers) must report suspected wrongdoing promptly and in good faith, based on a reasonable belief that misconduct has occurred.

2.2 Reporting Channels

• Primary Contact: Submit reports to the Corporation’s Secretary by email or in writing at the Board-designated address.
• Alternate Contacts: If the Secretary is implicated or unavailable, submit reports to the President or Treasurer.
• Anonymous Reporting: Anonymous reports may be submitted in writing to the Corporation’s principal office or via a secure online form, if available, with sufficient detail for investigation.
• External Reporting: If internal channels are ineffective, concerns may be reported to agencies like the IRS or DC Department of Licensing and Consumer Protection.

2.3 Report Content

Reports should include the nature of the concern, relevant dates, names of involved individuals, specific conduct, and any supporting documentation.

Article 3: Whistleblower Protections

3.1 No Retaliation

Individuals reporting in good faith or participating in investigations shall not face retaliation, such as dismissal, demotion, harassment, or adverse changes in affiliation terms. Retaliators may face disciplinary action, including termination or removal from the board.

3.2 Confidentiality

The Corporation will maintain confidentiality of the reporter’s identity and information, consistent with investigation needs and legal obligations.

3.3 Good Faith Requirement

Reports must be made in good faith. Knowingly false or malicious reports may lead to disciplinary action, but honest mistakes will not result in penalties.

Article 4: Investigation and Resolution

4.1 Acknowledgment

The designated officer will acknowledge receipt of a report within five business days, unless anonymous.

4.2 Investigation

Reports will be investigated promptly, fairly, and confidentially by the Board or a designated committee, with legal counsel engaged as needed.

4.3 Findings and Resolution

The Board will determine corrective actions and, where feasible, notify the whistleblower of the outcome, maintaining confidentiality.

4.4 Board Oversight

The Board will oversee all reports and investigations to ensure fair resolution.

Article 5: Administration

5.1 Documentation

The Corporation will maintain a confidential log of whistleblower reports and outcomes, per its Record Retention and Destruction Policy.

5.2 Distribution and Training

This policy will be distributed to all directors, officers, employees, and volunteers upon engagement and reviewed annually. It will be posted on the Corporation’s website for transparency.

5.3 Compliance and Indemnification

This policy supports compliance with federal and DC laws, including the Sarbanes-Oxley Act. Individuals acting in good faith may be eligible for indemnification under the Corporation’s bylaws.

Article 6: Amendments and Adoption

6.1 Amendments

This policy may be amended by a two-thirds vote of the Board, with seven days’ advance notice.