Whistleblower Policy

1. Purpose and Scope

International Medical Aid (IMA) is committed to the highest standards of ethics, legality, and transparency. This Whistleblower Policy is designed to encourage and enable all IMA personnel, including full-time and part-time staff, interns, volunteers, and contractors, to report serious concerns internally, allowing IMA to address and correct inappropriate conduct. The policy applies globally to all IMA sites and operations (including, but not limited to, the U.S., Peru, Kenya, etc.). It is designed to ensure compliance with U.S. whistleblower protection laws. 

Retaliation against whistleblowers is illegal under U.S. federal law, and IMA strictly prohibits any form of retaliatory action against anyone who, in good faith, reports misconduct or potential violations of law or policy.

2. Reporting Procedure

IMA maintains an “open door” environment and strongly encourages personnel to report any suspected illegal or unethical behavior, policy violations, financial improprieties, or other concerns without fear or hesitation. Whenever possible, individuals should first report concerns to their immediate supervisor or on-site program coordinator. Supervisors are expected to listen to concerns and, when appropriate, escalate issues through proper channels.

• If you are not comfortable speaking with your supervisor or believe the issue is not being adequately addressed, you may bypass the standard chain of command. In such cases, you are encouraged to report the concern directly to IMA leadership or the designated oversight body. This may include contacting IMA’s Chief Executive Officer, Vice Presidents, or a designated Whistleblower Committee responsible for handling such reports. You may also email your concern directly to IMA’s confidential compliance address at [email protected]. This inbox is monitored by IMA’s designated compliance personnel for receipt and review of whistleblower reports.
  
• Anonymous Reporting: IMA provides mechanisms for confidential or anonymous reporting. Violations or suspected violations may be reported confidentially by email to [email protected] or anonymously via this secure online form, if the reporting person prefers. All reports are treated as confidential to the fullest extent possible. Anonymous reports should contain as much detailed information as possible to facilitate a proper investigation.
  

All reports, whether submitted to a supervisor, an executive, or made anonymously, will be handled with appropriate confidentiality and urgency. Nothing in this policy limits your right to report issues to appropriate legal or regulatory authorities; however, we encourage attempting to resolve matters internally first so the organization can promptly address them.

3. Confidentiality and Anonymity

Reports of concerns will be kept confidential to the fullest extent possible, consistent with the need to investigate and resolve the issue. IMA will protect the identity of whistleblowers who wish to remain anonymous. 

Information about a report will only be shared with those who need to know in order to investigate or take appropriate action. Absolute confidentiality cannot be guaranteed in every circumstance (for example, if legal proceedings are initiated). Still, IMA will endeavor to protect your identity and not disclose it without your consent, unless required by law or regulation.

4. Protection from Retaliation

IMA strictly forbids retaliation against anyone who, in good faith, reports a concern or cooperates with an investigation. Retaliation includes intimidation, harassment, adverse employment actions, or any form of punishment for reporting a problem or concern. It is contrary to IMA’s core values for anyone to retaliate against an employee, intern, volunteer, or contractor for reporting an ethics violation or suspected illegal act in good faith.

• Any IMA personnel, including supervisors or managers, who retaliate against a whistleblower will face disciplinary action, up to and including termination of employment or dismissal from the program. This protection extends to those who assist in or participate in an investigation of reported wrongdoing.
  
• If you believe you have faced retaliation for reporting a concern, report this immediately (using any of the channels above). Such retaliatory behavior will be independently investigated and, if substantiated, will result in appropriate disciplinary measures.
  

These anti-retaliation provisions reflect not only IMA’s commitment to a safe reporting environment but also compliance with U.S. laws that protect whistleblowers. Federal law and many state laws prohibit companies and nonprofits from retaliating against employees who “blow the whistle,” and IMA fully abides by these protections.

5. Investigation and Resolution

IMA takes all reports of misconduct or wrongdoing seriously. Each concern raised under this policy will be promptly and fairly investigated by the appropriate party. Depending on the nature of the allegation, an investigation might be led by a designated Whistleblower Committee, a senior executive, a member of the Board, or an external independent investigator. The investigator(s) will gather facts, maintain confidentiality as much as possible, and determine whether the concern is substantiated and what corrective action may be needed.

Investigation process:

• Acknowledgement: If the report is not anonymous and the reporter’s identity is known, IMA will acknowledge receipt of the complaint (generally within a few business days) and may ask follow-up questions to ensure a thorough investigation.
  
• Fact-Finding: The responsible investigator will conduct a fact-finding process, which may include reviewing documents, interviewing individuals involved or witnesses, and consulting experts or legal counsel if necessary. All employees are expected to cooperate fully with any investigation (failure to cooperate may result in its own disciplinary action). During this process, confidentiality will be maintained as much as possible to protect both the reporter and any individuals implicated.
  
• Outcome: After investigating, IMA will take appropriate action based on the findings. This may include disciplinary action against wrongdoers, policy or procedural changes, training, or other remedies to address and correct the issue. Where appropriate, and if the reporting individual’s identity is known, IMA will inform the whistleblower of the general outcome of the investigation (recognizing that some details might be limited by privacy).
  
• Documentation: All complaints and investigation results will be documented and retained in accordance with our record-keeping policies. This ensures accountability and allows IMA’s leadership and Board (or relevant committee) to review patterns or serious issues that arise.
  

Throughout this process, IMA is committed to handling reports with due care and promptness, and to correcting any confirmed improper practices or violations. The objective is not only to resolve the specific issue but also to prevent future occurrences and maintain an ethical workplace.

6. Acting in Good Faith

When reporting a concern, IMA personnel are expected to act in good faith and have reasonable grounds for their report. This means that the individual truly believes there is a problem or violation based on the information they have. Deliberately making false or malicious allegations is prohibited. If an investigation reveals that a report was made in bad faith – for example, an accusation the reporter knew to be false – it will be viewed as a serious disciplinary offense.

Making a report in good faith, even if it turns out to be unsubstantiated after investigation, will not result in any punishment. IMA would much rather have concerns reported and investigated than have misconduct go unaddressed. 

All personnel should feel empowered to raise issues openly or anonymously, knowing that the organization is committed to hearing about problems and will protect those who speak up. This policy is designed to promote a culture of transparency and accountability, enabling us to address any issues promptly and collaboratively.

7. Types of Concerns to Report

This Whistleblower Policy covers a broad range of potential issues. You should report any conduct that you believe in good faith constitutes:

• Illegal or Unethical Acts – such as theft, fraud, embezzlement, bribery, or violation of any law or government regulation.
  
• Violations of IMA Policies or Code of Conduct – including harassment, discrimination, safety violations, or other serious misconduct that breaches our internal policies or ethical standards.
  
• Financial Improprieties – such as fraudulent accounting, falsifying financial documents, or providing false information in IMA’s records or public filings.
  
• Gross Mismanagement or Safety Concerns – for example, abuse of authority, unsafe practices endangering staff or the public, or substantial and specific dangers to employee or community health and safety.
  
• Any Other Serious Misconduct – including violations of medical ethics, abuse of beneficiaries or community members, conflicts of interest being concealed, etc.
  

These examples are not exhaustive. Any matter that causes you serious concern about the legality, ethics, or integrity of IMA’s operations should be raised. Organizations that encourage an open reporting culture, with a “no retaliation” standard, are more transparent and can address issues ranging from financial fraud to unsafe conditions or discrimination more effectively. By speaking up, you are helping IMA maintain its integrity and accountability to the communities we serve and to each other. For any questions about this policy or reporting options, contact IMA’s compliance team at [email protected].