Whistleblower Protection Policy

Midnight Golf Program requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Midnight Golf Program we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Midnight Golf Program can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, mentors and volunteers to report concerns about violations of Midnight Golf Program’s code of ethics or suspected violations of law or regulations that govern Midnight Golf Program’s operations.

No Retaliation

It is contrary to the values of the Midnight Golf Program for anyone to retaliate against any board member, officer, employee, mentor or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of MidnightGolf Program. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

Midnight Golf Program has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with thePresident/Executive Director or a Board Member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Midnight Golf Program’sPresident/Executive Director or Board Member who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the President/Executive Director or Board Member.

Compliance Officer*

Midnight Golf Program’s Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the President/Executive Director and the Board of Directors of all complaints and their resolution and will report at least annually to the Board Treasurer on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

Midnight Golf Program’s Compliance Officer shall immediately notify the Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.


Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

Midnight Golf Program’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Renee Fluker
Midnight Golf Program

*The Compliance Officer may be a board member, the President/Executive Director, or a third party designated by the organization to receive, investigate and respond to complaints.

Record Retention and Destruction Policy

1) Purpose

The  purpose of this Policy is to ensure that necessary records and documents of the Midnight Golf Program are adequately protected and maintained and to ensure  that records that are no longer needed by Midnight Golf Program or are of no value are discarded at the proper time. This Policy is also for the  purpose of aiding  employees of the organization in understanding their obligations in retaining  electronic documents -including e-mail, Web files, text  files,  sound and movie  files, PDF documents, and all Microsoft Office or other formatted files.

2) Policy

This Policy represents the Midnight Golf Program’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

3) Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Midnight Golf Program and the retention and disposal schedule of electronic documents. The“Administrator” (President/Executive Director) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorized to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for Midnight Golf Program; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

4) Suspension of Record Disposal In Event of Litigation or Claims

In the event the organization is served with any subpoena or request for  documents or any employee becomes aware of a governmental investigation or audit concerning Midnight Golf Program or the commencement of any litigation  against or concerning the organization, such employee shall inform the Administrator and any further disposal of documents shall be suspended until such  time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as are necessary to promptly inform all staff of any suspension in the further disposal of documents.

5) Applicability

This Policy applies to all physical records generated in the course of the organization’s operation, including both original documents and reproductions. It  does not apply to independent contractor records as we rely upon the governing  boards of third party vendors to set appropriate retention policies for their members. It also applies to the electronic documents described above.

Midnight Golf Program 990 (2017-2018)

Conflict of Interest Policy