Misconduct Reporting and Anti-Retaliation Policy

PURPOSE 

Conservation International (CI) is committed to the highest standard of ethical conduct within our organization and through our projects and activities with global partners. This includes the responsibility and requirement of individuals to comply with all applicable laws and regulations, the CI Code of Conduct, and core values of integrity, respect, courage, optimism, passion, and teamwork. To maintain our commitment, this policy outlines multiple methods to report concerns and how CI provides support and protection to those who report misconduct.

SCOPE

This Policy applies to all CI employees, interns, fellows, volunteers, and representatives (jointly, "CI Staff"), as well as CI grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/awardees, and representatives (jointly, "Delivery Partners") engaged by CI. Any community, organization, project stakeholder, or affected group that believes it may be negatively affected by CI’s work may submit a complaint.

OUR POSITION AND PRINCIPLES

We encourage a culture of openness where CI Staff, Delivery Partners, other stakeholders, individuals, and communities connected to CI can safely raise concerns and report unethical behavior.  

• Required Reporting and Cooperation: CI Staff are required to report suspected or actual violations of the law, CI’s policies, core values, or the Code of Conduct and cooperate in any resulting investigation. Such concerns include, but are not limited to, any conduct that violates human or legal rights; discrimination, harassment, or bullying; fraud, bribery, or corruption; issues of legal or regulatory compliance; substance abuse in the workplace; theft; and/or other individual or group behaviors that are inconsistent with CI’s Code of Conduct, values or policies, or which could pose a financial and/or legal risk to CI or threaten CI’s public image.
• Confidentiality: CI treats good faith reports of misconduct as “Protected Disclosures” and takes confidentiality and privacy seriously. This includes sharing information, including the identity of the reporter, with only Authorized Individuals, including the identity of the reporter with those who have a business need to know to effectively conduct any investigation and follow-up action or where there is a legal requirement to share a reporter’s identity.
• Protection from Retaliation: CI strictly prohibits and does not tolerate any Adverse Action against anyone who participates in an investigation, raises a legal or ethical concern, or makes a Protected Disclosure.

OUR ACTIONS

If you know of or have a good-faith reason to suspect misconduct, CI encourages everyone to speak up and report concerns. Reporting a concern is one way to ensure that people have a voice in the work of CI.

Reporting Procedure

For CI Staff, the following reporting methods are available: 

• To a trusted CI senior leader or direct supervisor if they are not directly involved in the concern or allegation.
• To the Chief People Officer, General Counsel, or any member of Risk Management at risk@conservation.org, any member of People and Culture at peopleandculture@conservation.org, or Local HR. 
• To CI’s confidential Ethics Line. The Ethics Line allows for confidential and anonymous reporting through a secure web portal or by toll-free local phone numbers. This is available 24/7 and provides multilingual reporting.
  

For external community members, stakeholders, or CI Delivery Partners, the following reporting methods are available:

• To the Project-level or Site-level Accountability and Grievance Mechanism.
• For grievances that are unable to be resolved at the project level or site level, email CI’s Risk Management and Compliance team at grievance@conservation.org or mail to Senior Director of Compliance, Conservation International 2011 Crystal Drive, Suite 600 Arlington, VA 22202, USA. 
• To CI’s confidential Ethics Line. The Ethics Line allows for confidential and anonymous reporting through a secure web portal or by toll-free local phone numbers. This is available 24/7 and provides multilingual reporting.
  

CI’s Ethics Line allows for anonymous reporting. Anonymous reporting requires the reporter to provide as much detail as possible to ensure that CI can conduct a thorough and effective investigation. Some local laws, including most European countries, discourage anonymous reporting and limit anonymity to only accounting and internal control issues, including fraud, inaccurate records, auditing, bribery and corruption, and other financial matters.

CI Response to Report

CI will promptly review matters reported and ensure no conflicts of interest exist during the process of reporting, investigation, or management response and action. Reports will be kept confidential to the extent possible, with the understanding that confidentiality may not be maintained where identification is required by law or in order to enable CI or law enforcement to conduct an adequate investigation. A project-level grievance is reviewed to understand whether a potential breach of CI’s environmental and social safeguards, principles, standards, or procedures has occurred.

As needed and based on the merits of the report, CI may proceed with an investigation. CI applies a standard administrative investigation process to ensure a structured, professional, and fair process for all individuals involved. All CI Staff are required to cooperate with a formal investigation, including the reporter. Should the reporter withdraw their report, CI may elect to continue the investigation to ensure compliance with CI policies, laws and regulations and to maintain a safe and ethical work environment. CI may provide a limited exception to this investigation or participation requirement for survivors of sexual abuse, exploitation, and harassment as part of CI’s survivor-centered approach and to prevent re-traumatization.

CI may put reasonable interim measures in place during an investigation if CI determines that such measures would be in the individual’s and/or CI’s best interest. These measures may include, but are not limited to, a leave of absence, suspension, or transfer of the individual who reportedly violated the policy, CI Code of Conduct or ethical standard. If an investigation confirms that a violation has occurred, CI will take appropriate action to correct and prevent its recurrence.

Protection from Retaliation

CI will not tolerate any form of retaliation against CI Staff who make a Protected Disclosure in good faith. Any individual who experiences, observes, or becomes aware of any conduct they believe may be retaliatory must immediately follow the Reporting Procedure.

Reports of retaliation will be investigated promptly in a manner consistent with a full and fair investigation. Whether an adverse action is retaliatory will depend on whether the action would have been taken for separate and legitimate reasons in the absence of the Protected Disclosure. If not, the action would generally be considered as having been motivated by retaliation.

Any CI Staff who engages in such retaliation will be subject to discipline up to and including termination of employment or contractual relationship with CI. Delivery Partners may be disqualified from submitting future funding proposals to CI.

DEFINITIONS

• Accountability and Grievance Mechanism: Local method to anticipate, collect, record, address, and, where possible, resolve grievances related to CI project activities. These mechanisms are designed to address local community concerns who believe that they have been harmed or have the potential to be harmed by a CI project activity.
• Adverse Action: Retaliation taken by CI or CI Staff for reporting a concern or participating in an investigation. This can range from termination, demotion, disciplining, failure to hire or rehire, reduction of pay or benefits, making threats, and falsely rating the individual’s performance to more subtle actions, such as isolating, ostracizing, or mocking.
• Anonymous: Unknown identity of the reporter. A reporter is anonymous when their identity is not known to any CI Staff, including during an investigation process. Ethics Line offers anonymous reporting to CI as an independent external party with systems and data privacy controls separate from the CI IT network.
• Authorized Individuals: Persons who are strictly necessary for the handling, investigation, and decision-making of a report or who must implement any corrective or disciplinary action as the result of a substantiated report.
• Confidential: Non-disclosure of certain information such as the identity of the reporter, the content of the concern as well as any other details related to the concern and any investigation of the concern. This also includes any information that relates to the identity of the reporter. Information is only shared on a strict business ‘need to know’ basis with authorized individuals.
• Good Faith: Filing a written complaint concerning a suspected or actual violation based on reasonable grounds for believing the information shared indicates a violation. Any allegations which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
• Grievance: Complaint about a potential or actual negative impact from a CI program or project. Examples of potential grievances include (but are not limited to) participation in or exclusion from a Project-led consultation, or the process of free, prior, and informed consent; harm to persons related to the effects of Project activities (waste or water pollution, noise, dust, disruption, etc.); adverse risks related to community health, safety and security (e.g., use of security personnel, road/traffic safety); and conflicts related to land and resource use restrictions affected by project activities.
• Protected Disclosure: Reporting, through the established CI channels, of any information about an incident that CI Staff reasonably and in good faith believes has occurred that violates the law, CI’s policies, core values, or the Code of Conduct to CI or a relevant government agency, court, or regulatory body. Examples included, but are not limited to, violations of applicable law, rules, or regulations, abuse of authority, gross waste of funds, gross mismanagement, or substantial and specific danger to public health and safety.
• Retaliation: Adverse action taken by CI or CI Staff as the result of the Protected Disclosure.