As approved by the Hepburn Library of Madrid’s Board of Trustees, December 7, 2021.

The Hepburn Library of Madrid is committed to upholding the highest standards of ethical, moral, and legal business conduct, as well as the commitment to open communication. All staff members, trustees, and volunteers are required to uphold high standards of business and personal ethics in the conduct of their duties and responsibilities.

All staff, board members, and volunteers acting in good faith are encouraged to report suspected or actual wrongful conduct, and are assured that reporting a legitimate concern will not result in termination or retaliation of any sort. This policy applies to all employees, volunteers, and agents of Hepburn Library of Madrid, including the Executive Director and the Board of Trustees.

The objectives of the Hepburn Library of Madrid Whistleblower and Ethical Behavior Policy are to establish standards of conduct and procedures for the submission of concerns, on a confidential basis, regarding:

  • Harassment and bullying which leads to the creation of a hostile work environment, and impacts an employee’s employment status or benefits;
  • Questionable accounting or auditing actions by employees, trustees, officers, or other stakeholders of the organization;
  • Wrongful conduct such as a violation of applicable State and/or Federal laws and regulations; a serious violation of any Hepburn Library of Madrid Policy; or the use of Hepburn Library of Madrid property, resources, or authority for personal gain or other non-library purpose, except as provided under Hepburn Library of Madrid policy.
  • The receipt, retention, and treatment of complaints received by the organization regarding harassment, accounting, internal controls, auditing matters, or other wrongful conduct.
  • Protection from retaliatory actions of trustees, employees, and volunteers reporting concerns.

Authority of the Board of Trustees

All concerns submitted in writing will be forwarded to the President of the Board of Trustees in accordance with the procedures set forth below. The President shall be responsible for designating the appropriate committee to investigate and make appropriate recommendations to the Board of Trustees with respect to the following: (a) concerns that originate from trustees and other non-employees or; (b) concerns submitted by employees that have not been resolved by the Hepburn Library of Madrid Executive Director to the satisfaction of the complainant.

Reporting Procedures and Corrective Action for Employees

Employees should first discuss their concern in confidence with their immediate supervisor. If, after speaking with his or her supervisor, the employee is convinced that his or her concern is unwarranted or that, in the opinion of the employee, the supervisor will take appropriate steps to resolve the employee’s concern, no further action is required by the employee.

However, further action is warranted if the employee:

(a) continues to have reasonable grounds to believe the concern is valid and that the response of his or her immediate supervisor was not adequate or;

(b) the immediate supervisor recommends that the issue should be referred to a higher level in the organization. In this situation the employee should write a formal complaint which the first level supervisor is obligated to take to the Library Executive Director (or Acting Library Director) within five working days.

The Executive Director shall promptly inform the employee of receipt of the complaint. A copy of the complaint shall be forwarded to the President of the Board of Trustees. The Executive Director shall investigate the circumstances of the complaint in a timely fashion and, where warranted, take disciplinary and/or other actions. At the completion of the investigation, the Executive Director shall provide the employee initiating the complaint and the President with a written summary of the action taken.

Notwithstanding the procedure stated above, if the employee’s supervisor is the subject of the employee’s concern or is possibly involved, the employee may choose to discuss their concern directly and in confidence with the Executive Director and then write a formal complaint. It is the responsibility of the Executive Director to investigate promptly the circumstances of the complaint in the manner stated in the previous paragraph.

In extraordinary circumstances, and after due consideration, an employee who suspects or believes that the Executive Director is involved in unethical or illegal behavior may take his or her concerns directly to the President of the Board of Trustees using the procedure below entitled “Reporting Procedures for Trustees and Other Volunteers.”

Reporting Procedures and Corrective Action for Individuals Not Employed by the Library

The Hepburn Library of Madrid trustees, volunteers, individuals in the member libraries of the NCLS network, as well as members of the general public, should submit concerns in writing directly to the President of the Board of Trustees. If the President of the Board of Trustees is not available or is the subject of the concern, the complaint should be directed to the Vice-President of the Board of Trustees.

The President shall be responsible for designating an appropriate committee, as circumstances dictate, to investigate and make recommendations to the Board of Trustees, with respect to all written concerns. The designated committee has the authority to retain outside legal counsel, accountants, private investigators, or any other source deemed necessary to conduct a full and complete investigation of the allegations.

The President shall inform the originator of the receipt of the written complaint.  All trustees of the library shall be informed of the nature of the complaint with emphasis on maintaining the confidentiality appropriate for personnel issues.

The Board of Trustees and its designated committee shall resolve all complaints in a timely fashion and inform the individual submitting the complaint of the Board’s final action.

Acting in Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates harassment or bullying, a questionable or improper accounting or auditing practice, an intentional violation or suspected violation of a library policy, or misconduct.

The act of making allegations which are proven to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in actions up to and including termination of employment or dismissal from the trustee or volunteer position.

Confidentiality

Reports of concerns and their investigations shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Disclosure of reports of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

No Retaliation Provision

This Whistleblower and Ethical Behavior Policy is intended to encourage and enable employees, trustees, volunteers and others to raise concerns within the Hepburn Library of Madrid for investigation and appropriate action. With this goal in mind, no trustee, employee or volunteer who, in good faith, reports a concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, an employee, trustee or volunteer who retaliates against someone who has reported a concern in good faith shall be subject to discipline, up to and including termination of employment or dismissal from the trustee or volunteer position.

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PDF of the Whistleblower and Ethical Behavior Policy

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