Summary 

It is the policy of the Population Council that the Council will not retaliate1 against any whistleblower2 who reports or undertakes protected actions3 based on a reasonable belief that an activity, policy or practice of the Council is illegal4 or unethical5.

This policy provides information about the procedures for making whistleblower reports; examples of the types of matters that should be reported; information about the investigation of such reports; and information about what the Council will do if a whistleblower is threatened and/or retaliated against by another staff member(s) because of the report.

This policy is intended to reinforce the Council’s commitment to conducting all of its activities in accordance with the highest legal and ethical standards, and its requirement that all Council related activities are carried out in accordance with those standards.

This policy is divided into the following sections:

  1. Procedures for Reporting Illegal and/or Unethical Matters
    1. Reports to be Made Directly to the Immediate Supervisor
    2. Reports to be Made Directly to the President
    3. Reports to be Made Directly to the Chairperson of the Board of Trustees
    4. Form of Submitting Reports
    5. Ability to Report Financial Misconduct6 Directly to the Chairperson of the Audit Committee of the Board of Trustees
    6. Ability to Report Illegal and/or Unethical Matters to an Outside Firm
  2.  Examples of the Types of Matters that Should be Reported
  3. Investigation of Reports
    1. Responsibility for Investigating Reports
      1. Director or Executive Team Member Responsible for the Investigation
      2. President Responsible for the Investigation
      3. Executive Committee of the Board of Trustees Responsible for
        the Investigation
      4. Audit Committee of the Board of Trustees Responsible for the
        Investigation
    2. Time Frame for Investigating Reports
  4. Confidentiality
  5. Disclosure of Results of an Investigation
  6. Disciplinary Measures for Threats and/or Retaliation against Whistleblower
  7. Bad Faith Reports or Reports Not Based on Reasonable Beliefs
  8. Record Keeping
  9. Questions
  10. Effective Date

I. PROCEDURES FOR REPORTING ILLEGAL AND/OR UNETHICAL MATTERS

A. Reports to be Made Directly to the Immediate Supervisor

A whistleblower who wishes to make a report about an illegal or unethical policy, activity, or practice of the Council or an illegal or unethical activity of another staff member that is related to the Council, should report the matter directly to his or her immediate supervisor. Likewise, a whistleblower who is threatened and/or retaliated against by another staff member because he or she made such a report, should report the matter to his or her immediate supervisor.

A supervisor who receives a report about any of the foregoing matters must inform the country director (if applicable), director, and executive team member in charge of the program, division or office in which the staff member is employed no later than one (1) business day after the supervisor received the report. Whenever an executive team member receives a report that concerns financial misconduct they must report the matter to the president within one (1) business day after he or she received the report.

B. Reports to be Made Directly to the President

If a whistleblower wishes to report misconduct in science7, the whistleblower should report the matter directly to the president. Also, although whistleblowers who report directly to a director or executive team member should report illegal or unethical matters to that director or executive team member, if that individual is or may be involved in the matter, the whistleblower should report the matter directly to the president. The president must then promptly inform the chairperson of the board of trustees about the matter. Whenever the president receives a report that concerns financial misconduct, the president must then promptly inform the chairperson of the audit committee of the board of trustees about the matter.

C. Reports to be Made Directly to the Chairperson of the Board of Trustees

If a whistleblower reports directly to the president and the president is or may be involved in an illegal or unethical matter, then the whistleblower should report the matter directly to the chairperson of the board of trustees. The chairperson of the board of trustees must then inform the other members of the executive committee of the board of trustees about the matter.

D. Form of Submitting Reports

Whistleblowers may make their reports about illegal or unethical matters in writing, in person, by telephone, or by electronic or other mail.

E. Ability to Report Financial Misconduct Directly to the Chairperson of the Audit Committee of the Board of Trustees

A whistleblower who wishes to make a good faith report concerning financial misconduct may report the matter directly to the chairperson of the audit committee of the board of trustees instead of reporting it in accordance with the procedures set forth above. The report to the chairperson of the audit committee may be made in writing, in person, by telephone, or by electronic or other mail. In addition, the report may be made anonymously.

F. Ability to Report Illegal and/or Unethical Matters to an Outside Firm 

If a whistleblower wishes to make a good faith report concerning any misconduct, illegal and/or unethical matter, the whistleblower has the option of remaining anonymous and contacting an outside employee communications management firm—Navex Global, instead of reporting it in accordance with the procedures set forth above.  This service, called EthicsPoint, can be accessed anywhere in the world, 24 hours per day, 7 days a week, via the web portal found at this link.

EthicsPoint will manage the collection of information from whistleblowers who access the service, and then pass along the reports to the Council. Depending on where you are located, you may be able to make a report by phone using a toll-free number, instead of submitting a report through the web portal. Use the drop-down menu to determine which reporting method(s) are available in your country.

Both methods allow the whistleblower to remain anonymous or to choose to identify themself. Regardless of the method of reporting, EthicsPoint will then create electronic reports based upon staff member replies to specific questions, which are forwarded to the appropriate person at the Council. You will also receive a REPORT KEY number. You will need your report key (and the password you selected) to check on your report in the future or to make a follow-up.

II. EXAMPLES OF THE TYPES OF MATTERS THAT SHOULD BE REPORTED

The following is a non-exhaustive list of the types of matters that should be reported:

  • A Council policy, activity, or practice that creates a danger to public health or safety;
  • Violation of the Council’s Institutional Financial Conflicts of Interest in Research Policy8;
  • Violation of the Population Council’s Conflicts of Interest Policy or the Population Council, Inc.’s Trustees and Officers Conflicts of Interest Policy;
  • Violation of the Population Council’s Discrimination, Harassment and Retaliation Policy9;
  • Unauthorized use or theft of Council funds;
  • Theft of Council equipment or goods;
  • Payment for services or goods that are not rendered or delivered;
  • Forgery or alteration of documents including checks, agreements, time sheets, purchase orders, etc.;
  • Unauthorized disclosure of confidential or proprietary information to outside parties;
  • Intentionally providing false or misleading information to or withholding material information from the Council’s auditors or trustees;
  • Intentionally providing false or misleading information to governmental agencies;
  • Intentionally plagiarizing, fabricating, and/or falsifying research data;
  • Threat(s) and/or retaliation against a whistleblower because they made a good faith report or participated in an investigation that is covered by this whistleblower policy;
  • Assisting with or concealing any of the above or similar activities.

III. INVESTIGATION OF REPORTS

A. Responsibility for Investigating Reports

1.  Director or executive team member responsible for investigation

If a whistleblower other than an executive team member is to be investigated, the President will appoint a director or executive team member outside of the program, division or office where such whistleblower is employed to conduct the investigation. The director or executive team member may also appoint a designee to assist with the conduct of the investigation. The results of the investigation and the reasons for corrective action or no action must be documented by the investigators, who will inform and consult with relevant third parties (e.g. Director, Human Resources, General Counsel) as appropriate concerning the matter.

2. President responsible for investigation

If the matter to be investigated concerns misconduct in science, the president must ensure that the requirements for investigating such matters that are set forth in the Council’s Misconduct in Science Policy are followed10. Also, if an executive team member is to be investigated, the president, in consultation with the chairperson of the board of trustees, will be responsible for the conduct of the investigation. The president and/or the chairperson of the board of trustees must inform the other members of the board of trustees about the investigation and will make recommendations to the board of trustees that are based upon the findings of the investigation. The board of trustees will determine if corrective action should be taken or if no action should be taken. The results of the investigation and the board of trustees’ reasons for corrective action or no action must be documented by the board.

3. Executive Committee of the Board of Trustees responsible for investigation

If the president is to be investigated, the executive committee of the board of trustees will be responsible for the conduct of the investigation. The executive committee must inform the other members of the board of trustees about the investigation and will make recommendations to the board of trustees that are based upon the findings of the investigation. The board of trustees will determine if corrective action should be taken or if no action should be taken. The results of the investigation and the board of trustees’ reasons for corrective action or no action must be documented by the board.

4. Audit Committee of the Board of Trustees responsible for investigation

Whenever the matter to be investigated is about financial misconduct or when the matter under investigation includes financial misconduct as well as other unethical or illegal activities, the audit committee of the board of trustees will be responsible for the conduct of the investigation. The audit committee must inform the other members of the board of trustees about the investigation and will make recommendations to the board of trustees that are based upon the findings of the investigation. The board of trustees will determine if corrective action should be taken or if no action should be taken. The results of the investigation and the board of trustees’ reasons for corrective action or no action must be documented by the board.

B. Timeframe for Conducting Investigation

The investigation of a report must commence no later than ten (10) business days after it was made by a staff member. Best efforts must be used to conclude an investigation within ninety (90) days after it was commenced.

IV. CONFIDENTIALITY

The Council will keep the identity of the whistleblower who reported the matter and the identities of the other staff members who participate in an investigation confidential. However, it is important to note that the Council’s commitment to being thorough in its investigation means that it cannot always guarantee confidentiality. Staff members and members of the board of trustees who have been informed about and/or involved in an investigation will be required to keep the matter confidential.

V. DISCLOSURE OF RESULTS OF AN INVESTIGATION

The results of an investigation will be disclosed if such disclosure is deemed appropriate by the Council.

VI. DISCIPLINARY MEASURES FOR THREATS AND/OR RETALIATION AGAINST WHISTLEBLOWER

In order to reinforce the Council’s prohibition against retaliation against whistleblowers who make reports about matters that that are covered by this policy, the Council will impose disciplinary measures, up to and including termination, against any staff member who is found to have retaliated or otherwise threatened, discharged, suspended, demoted, or taken any other adverse employment action against a whistleblower in violation of this policy.

VII. BAD FAITH REPORTS OR REPORTS NOT BASED ON REASONABLE BELIEFS

This whistleblower policy is intended to promote legal and ethical behavior. It cannot be used by a whistleblower to justify or excuse a report that is made in bad faith or is not based on a reasonable belief that Council is violating a law, rule, regulation, executive order or judicial or administrative order or ruling, or a reasonable belief that the Council’s activity or policy poses a substantial and specific danger to public health or safety. Therefore, if the Council’s investigation establishes that a whistleblower made a report in bad faith or without reasonable belief in its factual basis, the Council will impose disciplinary measures, up to and including termination, against the whistleblower.

VIII. RECORD KEEPING

All records concerning matters arising under this policy shall be maintained by the Human Resources office for a period of three years after the termination of the investigation.

IX. QUESTIONS

Questions concerning this policy should be directed to the general counsel.

X. EFFECTIVE DATE

This policy became effective on October 22, 2025 when approved by the co-presidents. This policy supersedes any and all prior statements of the Council on this matter. This policy may be amended from time to time by the president as they deem necessary, and as required by law.

  1. Retaliate means to harass, discriminate, intimidate, or threaten to or to take any other adverse action against a whistleblower because they made a report that is covered by this policy. In the case of employees, adverse actions include:
    1. adverse employment actions or threats to take such adverse employment actions against an employee in the terms of conditions of employment including but not limited to discharge, suspension, or demotion;
    2. actions or threats to take such actions that would adversely impact a former employee’s current or future employment; or
    3. threatening to contact or contacting United States immigration authorities or otherwise reporting or threatening to report to a government agency an employee’s suspected citizenship or immigration status or the suspected citizenship or immigration status of an employee’s family or household member.
  2. This policy protects any whistleblower that performed or is performing services for the Council, including exempt, non-exempt, full-time, and part-time employees of the Council; former employees; directors; persons seconded to the Council; fellows; interns; volunteers; contractors and former contractors.
  3. Reports and protected actions must be based on the whistleblower’s reasonable belief that the Council is violating a law, rule, regulation, executive order or judicial or administrative order or ruling, or that the Council’s activity or policy poses a substantial and specific danger to public health or safety. Protected actions include:
    1. disclosing or threatening to disclose to a supervisor or public body an activity, policy, or practice of the Council that the whistleblower reasonably believes violates the law or poses a substantial and specific danger to public health or safety;
    2. providing information to, or testifying before, any public body conducting an investigation into any such activity, policy, or practice by the employer; or
    3. objecting to, or refusing to participate in any such activity, policy or practice.
  4. An illegal activity is an activity that violates a law, rule, regulation, executive order or judicial or administrative order or ruling.
  5. An unethical activity is an activity that violates the standards of business and professional conduct that are set forth in the Council’s global Employee Conduct Guidelines. These Guidelines are available on the intranet.
  6. Financial misconduct includes theft of or the unauthorized use of Council funds, intentionally disregarding Council internal financial controls, or engaging in financial, accounting, disclosure, or auditing practices that significantly deviate from generally accepted financial, accounting, disclosure, or auditing standards for not-for-profit research organizations.
  7. Misconduct in science includes acts of fabricating, falsifying, plagiarizing, or engaging in other practices that seriously deviate from those that are commonly accepted within the research community for proposing, conducting, or reporting research. It does not include honest error or honest differences in interpretation of data. A copy of the Council’s Misconduct in Science Policy can be found on the Council intranet.
  8. Copies of all the conflicts of interest policies that are mentioned in this policy are available on the intranet.
  9. A copy of the Council’s Discrimination, Harassment and Retaliation Policy can be found on the intranet.
  10. Note that the Population Council’s Misconduct in Science Policy also requires that the Council’s Standing Committee on Research Integrity must participate in the investigation of misconduct in science matters. The Council’s Institutional Review Board must also be kept appropriately informed about investigations concerning misconduct in science.

Last update: 22 October 2025

Contact Email: hr@popcouncil.org