Whistleblower Policy
NORTH TORONTO SOCCER CLUB WHISTLEBLOWER POLICY
Purpose
The purpose of this Policy is to allow officers, employees, and volunteers of North Toronto Soccer Club (“NTSC)” to have a procedure by which they can discretely disclose incidents of wrongdoing without fear of reprisal.
Wrongdoing
Wrongdoing under this Policy refers to:
- Conduct that violates the law, including directing an individual to engage in illegal conduct
- Fraud or any other financial wrongdoing
- Conduct that places the health or safety of a player, volunteer, or employee at risks beyond those inherent in the sport
- An intentional or serious breach of the policies and codes of conduct adopted by NTSC as outlined at www.ntsoccer.com/Governance-Policies/ClubPolices
Reporting Wrongdoing
Any NTSC officer, employee, or volunteer who has a genuine belief that an incident of wrongdoing has occurred is encouraged to contact the Chair of the NTSC Board of Directors (“Chair”); contact coordinates found at:
www.ntsoccer.com/Governance-Policies/governance/board
with particulars of the suspected wrongdoing, including:
- the conduct that gives rise to belief of wrongdoing, including the person(s) alleged to have engaged in the wrongdoing
- the identifies of other persons (if any) who may be aware of, affected by or complicit in, the wrongdoing
- why the conduct gives rise to a belief of wrongdoing
Insufficient particulars of the conduct may limit the extent to which the belief of a wrongdoing can be investigated.
A person reporting wrongdoing is encouraged (but not required) to identify themselves and to provide their contact information so additional information (if necessary) may be gathered.
The Chair will not voluntarily disclose the identity of the person reporting a wrongdoing under this Policy to anyone without that person’s written consent, unless required by law or where the imminent health and safety of a minor requires such disclosure in the good faith opinion of the Chair.
Process Following Report
The Chair will determine whether an investigation is warranted and how such investigation will be undertaken, including where appropriate referring such investigation to be carried out by independent, third-party advisors. The Chair may defer making such determination until she/he has consulted with other NTSC directors (where such consultation is appropriate).
The Chair will provide at the next Board of Directors meeting (or sooner if the circumstances require) a summary of all reporting received under this Policy and the Chair’s course of action, including where applicable the status or outcome of any investigation undertaken.
Subject to the nature of the reported wrongdoing, the Board of Directors may decide to hear the Chair’s report without the presence of NTSC officers and employees otherwise participating in the meeting.
The Board of Directors will determine whether any additional investigation is required and, if not, decide what course of action (if any) shall be taken based on the results of the investigation.
Where the person reporting a wrongdoing has identified herself/himself and provided contact information, the Board of Directors will exercise their judgment whether or not to report to that person the course of action (if any) the Board of Directors has decided to take.
Depending on the nature of the reported conduct, the Chair and/or Board of Directors may be legally required or otherwise find it appropriate to refer the matter directly to law enforcement agencies.
Safeguards
If a NTSC officer, employee, or volunteer reports in good faith suspected wrongdoing under this Policy and the allegation is not confirmed by subsequent investigation, no action will be taken against that individual. Action may only be taken against an individual, including disciplinary action, where it is found, based on evidence, that a report was submitted under this Policy by an individual without a genuine belief of suspected wrongdoing and made for ulterior reasons.
Any attempt to retaliate or harass against an individual who has reported in good faith a suspected wrongdoing will not be tolerated by NTSC and will result in disciplinary action, including possible dismissal with cause, against any person(s) engaging in such retaliation or harassment.
September 2021