The Period Pantry.

1. Purpose

The Period Pantry (the “Organization”) is committed to conducting its activities with honesty, integrity, accountability, and in compliance with applicable laws and regulations. This Whistleblower Policy is intended to encourage and enable employees, officers, directors, volunteers, interns, student ambassadors, contractors, consultants, grant or program partners, and other representatives of the Organization to report concerns about suspected or actual wrongdoing without fear of retaliation.

The purposes of this Policy are to:

1. Encourage the timely reporting of suspected or actual violations of law, regulation, policy, or ethical standards.
2. Provide clear procedures for receiving, reviewing, investigating, and resolving reports.
3. Protect individuals who make good-faith reports from retaliation, harassment, intimidation, or adverse employment or organizational consequences.
4. Promote responsible stewardship of the Organization’s charitable assets, grant funds, records, and reputation.
5. Support a culture in which concerns may be raised and addressed fairly, promptly, and confidentially to the extent possible.

2. Scope

This Policy applies to all individuals and entities who perform services for, represent, govern, or participate in the activities of the Organization, including:

• Employees;
• Officers and directors;
• Volunteers;
• Interns;
• Student ambassadors;
• Contractors and consultants;
• Grant or program partners; and
• Other representatives of the Organization.

Individuals who are not covered by this list may also submit a report concerning the Organization or its representatives. The Organization will determine the appropriate process for reviewing such a report.

3. Reportable Conduct

Reportable conduct includes a suspected or actual violation of law, regulation, this Policy, another Organization policy, or generally accepted standards of ethical conduct. Examples include:

• Fraud, theft, embezzlement, misappropriation, or misuse of Organization funds, property, supplies, equipment, or other assets;
• Falsification, alteration, concealment, or improper destruction of financial, program, grant, personnel, volunteer, or other Organization records;
• Improper accounting, auditing, financial reporting, expense reimbursement, fundraising, or grant reporting practices;
• Bribery, kickbacks, undisclosed conflicts of interest, self-dealing, or other improper personal or financial benefit connected to Organization activities;
• Knowingly submitting false information to a government agency, funder, auditor, donor, partner, or the Board of Directors;
• Violations of federal, state, or local law, including laws governing nonprofit organizations, charitable solicitations, employment, safety, privacy, and grants;
• Conduct that places the health, safety, or welfare of clients, volunteers, employees, students, partners, or members of the public at unreasonable risk;
• Retaliation, harassment, intimidation, discrimination, threats, or interference directed at a person because that person raised a concern, participated in a review, or otherwise exercised rights under this Policy; and
• Any other serious misconduct or abuse of authority that could harm the Organization, its mission, the people it serves, or public trust in the Organization.

4. Matters Generally Outside This Policy

This Policy is intended for serious concerns involving suspected wrongdoing or violations described in Section 3. It is not intended to replace ordinary channels for addressing routine workplace or program matters, including ordinary performance feedback, scheduling questions, interpersonal disagreements, requests for clarification, or general suggestions about Organization programs.

Individuals should use the Organization’s ordinary supervisory, human resources, volunteer, or program procedures for those matters whenever appropriate. A concern that begins as a routine matter may nevertheless be handled under this Policy if the facts suggest fraud, a legal or policy violation, a serious safety concern, retaliation, or other reportable conduct.

5. Reporting Procedures

A report may be made orally or in writing. Reports should include as much specific information as reasonably available, including the nature of the concern, the individuals involved, relevant dates and locations, the names of witnesses, and any documents or other evidence that may assist with review. A person does not need to have proof of wrongdoing to make a report; a reasonable, good-faith concern is sufficient.

Reports may be submitted through any of the following channels:

1. Immediate Supervisor: Report to the Immediate Supervisor: [Name and Title], at [Contact Information].
2. Executive Director: Report to Executive Director Leanne Listman at [Contact Information].
3. Board President: Report to the Board President: [Name], at [Contact Information].
4. Anonymous Reporting Channel: Reports may be submitted anonymously through [Anonymous Reporting Method].

If a person is uncomfortable reporting to a particular channel, believes that channel is implicated in the concern, or does not receive an appropriate response, the person may report to any other channel listed above. The Organization will make reasonable efforts to keep the identity of a reporting person confidential, consistent with Section 7.

6. Reports Involving the Executive Director or Board Member

A report involving the Executive Director, a director, an officer, the Board President, or any other person who would ordinarily receive or oversee the report must be submitted to a disinterested member of the Board of Directors or through the Anonymous Reporting Channel. The person who is the subject of the report must not receive the report, direct the review, participate in decisions about the review, or access confidential information except as necessary to respond to the allegations and as authorized by the disinterested decision-makers.

When appropriate, the Board of Directors may appoint a committee of disinterested directors, an independent investigator, legal counsel, an auditor, or another qualified adviser to receive, review, investigate, or resolve the matter.

7. Confidentiality

The Organization will make reasonable efforts to protect the confidentiality of a report, the identity of the reporting person, the identity of witnesses, and information gathered during a review. Information will be shared only with individuals who have a legitimate need to know, such as those responsible for receiving, investigating, obtaining legal advice about, or resolving the report.

Confidentiality cannot be guaranteed in every circumstance. The Organization may disclose information when necessary to conduct a fair investigation, respond to allegations, protect health or safety, comply with a legal obligation, cooperate with law enforcement or a regulator, or protect the rights and interests of the Organization and the people it serves. The Organization will not attempt to identify an anonymous reporter unless permitted or required by law or necessary to address an immediate and serious threat.

8. Protection Against Retaliation

The Organization prohibits retaliation against any person who, in good faith, reports suspected or actual misconduct; asks a question or raises a concern about possible wrongdoing; participates in an investigation, audit, or review; provides information to a government agency; or exercises any other right protected by law or this Policy.

Retaliation is any adverse action or threat of an adverse action taken because a person engaged in protected activity. Retaliation is prohibited even if the concern is ultimately not substantiated. Examples of prohibited retaliation include:

• Termination, demotion, suspension, reduction of hours, or denial of an opportunity;
• Unfavorable changes in assignments, duties, compensation, scheduling, supervision, or access to Organization programs;
• Exclusion, harassment, bullying, intimidation, threats, or hostile treatment;
• Interference with a volunteer placement, internship, student ambassador role, contract, consulting engagement, grant, partnership, or other Organization relationship; and
• Threatening to take, or taking, any action intended to discourage a person from making a good-faith report or participating in a review.

A person who believes they have experienced retaliation should report it promptly through any reporting channel in Section 5. A substantiated violation of this anti-retaliation provision may result in corrective action, up to and including termination of employment or a relationship with the Organization, removal from a position, or termination of a contract or partnership.

9. Good-Faith Reporting

A person makes a report in good faith when the person reasonably believes that the information reported may indicate reportable conduct and provides the information honestly. A person is not required to be correct, to conduct an investigation, or to prove the concern before reporting it.

A report is not made in good faith when it is knowingly false, intentionally misleading, made with reckless disregard for the truth, or submitted primarily to harass or harm another person. A person who knowingly makes a false report or intentionally misuses this Policy may be subject to appropriate corrective action. An unsubstantiated report, standing alone, is not evidence that the report was made in bad faith.

10. Receipt and Initial Review of Reports

The person who receives a report will acknowledge receipt when the reporting person has provided contact information, generally within seven (7) business days. The recipient will promptly document the report and conduct, or arrange for, an initial review to determine the nature and scope of the concern, whether immediate action is needed, whether a conflict of interest exists, and who should oversee the matter.

The Organization may take interim measures when appropriate, including safeguarding records or assets, protecting a reporting person or witness, separating individuals, pausing a transaction, or notifying an insurer, regulator, law enforcement agency, or other authority. The Organization will not promise a particular result or disclose confidential information beyond what is appropriate.

When a report does not concern reportable conduct, the Organization may refer it to a more appropriate process and, when possible, inform the reporting person of that referral. When a report does concern reportable conduct, the Organization will proceed under Section 11.

11. Investigation Process

The Organization will investigate reports as promptly and fairly as practical, taking into account the nature, seriousness, complexity, and urgency of the concern. The investigator may interview the reporting person, the subject of the report, and witnesses; review relevant records; consult with legal counsel, an auditor, a human resources adviser, or another qualified professional; and take other reasonable steps to establish the facts.

The subject of a report will be given a fair opportunity to respond to the allegations, consistent with the need to protect evidence, confidentiality, and the integrity of the investigation. Individuals involved in a review are expected to cooperate, preserve relevant information, provide truthful information, and maintain confidentiality.

At the conclusion of the review, the investigator or designated decision-maker will document the findings and recommend or take appropriate corrective action. Corrective action may include training, policy or process changes, repayment or recovery of funds, discipline, removal from a role, termination of employment or a relationship with the Organization, reporting to a government agency, or referral to law enforcement. The Organization will communicate the outcome to the reporting person when appropriate and legally permissible, but may not be able to provide details about confidential personnel or legal matters.

12. Board Oversight

The Board of Directors has ultimate oversight responsibility for this Policy and for reports that involve the Executive Director, a director, an officer, or other senior leadership, or that present a significant legal, financial, safety, or reputational risk. The Board, or a committee designated by the Board, will receive periodic reports about the operation of this Policy, including the number and general nature of reports, the status of significant investigations, and material corrective actions, while preserving confidentiality.

The Board will ensure that individuals responsible for receiving or investigating reports are disinterested and appropriately qualified. A director or officer with an actual or potential conflict of interest must disclose the conflict and recuse themselves from the matter as required by the Organization’s conflict-of-interest practices.

13. Financial and Grant-Related Matters

Reports involving financial statements, internal controls, charitable contributions, restricted funds, grants, government funds, donor funds, procurement, reimbursements, or other financial or grant-related matters will be handled with particular care. The Organization will preserve relevant records and may promptly notify the Board Treasurer, the Board of Directors, an independent auditor, a grantor, a government agency, law enforcement, legal counsel, or another appropriate authority when required or advisable.

No person may conceal, alter, destroy, or remove records relevant to a financial or grant-related report. The Organization will correct material errors, return or redirect funds when appropriate, and make required disclosures or amended filings in consultation with qualified advisers.

14. Record Retention

The Organization will maintain reports received under this Policy, records of the initial review, investigation materials, findings, and corrective actions in a secure location with access limited to authorized individuals. Records will be retained for at least [three (3)] years after the matter is closed, or longer if required by law, a grant agreement, an audit hold, a litigation hold, an investigation, or another applicable record-retention requirement.

No record relevant to a pending or reasonably anticipated investigation, audit, claim, legal proceeding, or government inquiry may be destroyed or altered. Records will be disposed of securely when the applicable retention period has expired and no hold or other requirement applies.

15. No Waiver of Legal Rights

Nothing in this Policy limits, waives, or prevents a person from reporting suspected wrongdoing to a government agency, law enforcement, an inspector general, a regulatory authority, or another entity authorized to receive the report. Nothing in this Policy requires a person to report internally before contacting an external authority, and nothing prohibits a person from seeking independent legal advice.

This Policy does not create a contract of employment, guarantee continued employment or participation, or alter any at-will employment relationship to the extent permitted by law. The rights and protections provided by applicable law remain in effect regardless of this Policy.

16. Relationship to IRS Requirements and Maryland Law

This Policy is intended to support the Organization’s responsibilities as a tax-exempt organization, including the expectation that the Organization maintains accurate books and records, protects charitable assets, identifies and addresses conflicts of interest, and responds appropriately to concerns involving financial reporting and governance. This Policy will be administered consistently with applicable requirements of the Internal Revenue Code and related IRS guidance, including requirements relevant to tax-exempt organizations and Form 990 reporting.

This Policy will also be administered consistently with applicable federal, state, and local law, including Maryland law. If a provision of this Policy conflicts with a requirement of applicable law, the legal requirement will control and the remaining provisions will continue to apply to the fullest extent permitted.

17. Distribution and Training

The Organization will make this Policy available to employees, officers, directors, volunteers, interns, student ambassadors, contractors, consultants, grant or program partners, and other representatives as appropriate to their relationship with the Organization. The Organization may distribute the Policy electronically, in print, through an orientation or onboarding process, or through the Organization’s website or other communication channel.

The Organization will provide information or training about this Policy and the available reporting channels as appropriate. Individuals in supervisory, financial, governance, or other positions responsible for receiving concerns may receive additional training on documentation, confidentiality, conflicts of interest, anti-retaliation, and escalation requirements.

18. Amendments

The Board of Directors may amend, suspend, or rescind this Policy at any time, subject to applicable law and the Organization’s governing documents. The Executive Director may recommend amendments and may make administrative updates that do not change the substance of the Policy, subject to Board review and approval when required.

Material amendments will be communicated to the individuals and entities covered by this Policy. The current version of the Policy will be maintained in the Organization’s records and made available through the Organization’s designated communication channels.

19. Governing Law

This Policy shall be interpreted, construed, and governed in accordance with the laws of the State of Maryland, without regard to its conflict of laws principles, except to the extent that applicable federal law controls. Any dispute concerning the interpretation or administration of this Policy shall be addressed by the Board of Directors or its designee, subject to the rights and protections provided by applicable law.

20. Acknowledgment and Approval

This Whistleblower Policy was reviewed and approved by the Board of Directors of The Period Pantry on August 1, 2026. The undersigned acknowledge the approval and adoption of this Policy on behalf of the Organization.