Whistleblower Policy

Bangladesh Nature Foundation (BNF)

Head Office: Sayman Road, Cox’s Bazar-4700, Bangladesh

Established: 2010

Registration Deed No.: 17789, Chittagong Government Registrar, Court Building, Lal Dighi, Chittagong

Effective Date: 01 January 2010

Last Updated: 16 September 2026

1. Introduction

Bangladesh Nature Foundation (BNF) is committed to maintaining high standards of integrity, accountability, transparency, ethical conduct, environmental responsibility, and responsible stewardship of organizational and project resources. BNF recognizes that employees, volunteers, consultants, researchers, community representatives, project participants, partners, suppliers, and other stakeholders may become aware of misconduct, wrongdoing, misuse of resources, or risks that may not otherwise be identified through normal management and monitoring systems.

This Whistleblower Policy provides a safe and appropriate framework for raising genuine concerns about suspected wrongdoing. BNF encourages individuals to report concerns in good faith and aims to ensure that such concerns are handled fairly, confidentially, promptly, and without retaliation. The purpose of this policy is not to encourage unfounded accusations. It is to ensure that people who reasonably believe that serious wrongdoing has occurred, is occurring, or may occur have an appropriate channel through which to raise their concerns.

2. Purpose of the Policy

The purposes of this policy are to:

  • encourage the reporting of genuine concerns about wrongdoing;
  • provide accessible channels for raising concerns;
  • protect whistleblowers and good-faith reporters from retaliation;
  • maintain confidentiality to the extent reasonably possible;
  • ensure concerns are assessed and investigated appropriately;
  • protect BNF’s funds, assets, people, projects, information, and reputation;
  • strengthen organizational accountability and internal controls;
  • identify and address weaknesses that may permit misconduct;
  • ensure that reported concerns are handled fairly and objectively; and
  • promote a culture in which ethical concerns can be raised without fear.

3. Scope

This policy applies to concerns relating to BNF’s governance, administration, projects, finances, research, conservation activities, community programs, partnerships, procurement, fundraising, employment, and other organizational activities. It applies to:

  • General Committee members;
  • Executive Committee members;
  • the Executive Director;
  • management and project personnel;
  • employees and temporary personnel;
  • consultants and technical experts;
  • researchers and research collaborators;
  • volunteers and interns;
  • contractors and suppliers;
  • implementing partners;
  • community representatives involved in BNF activities; and
  • other persons who have a legitimate relationship with BNF or its activities.

A person does not need to be an employee of BNF to raise a legitimate concern under this policy.

4. What Is Whistleblowing?

Whistleblowing is the reporting or disclosure of information concerning suspected wrongdoing, misconduct, serious organizational risk, or other matters of legitimate concern to an appropriate person or channel. A whistleblower may report a concern based on information personally observed, received, documented, or otherwise reasonably believed to be credible. Whistleblowing may involve concerns that affect BNF directly or concerns arising from projects, partners, contractors, suppliers, community activities, research activities, or the use of BNF or donor resources.

5. Matters That May Be Reported

Concerns that may be reported under this policy include, but are not limited to:

5.1 Fraud and Corruption

  • theft or misappropriation of funds;
  • bribery or attempted bribery;
  • kickbacks or undisclosed commissions;
  • fraudulent financial claims;
  • falsification of financial records;
  • fictitious transactions;
  • manipulation of procurement processes;
  • unauthorized use of organizational funds; and
  • deliberate concealment of financial misconduct.

5.2 Misuse of Organizational Resources

Concerns may include the misuse or unauthorized use of:

  • money;
  • vehicles;
  • equipment;
  • property;
  • project materials;
  • organizational accounts;
  • confidential information;
  • research data; or
  • other BNF resources.

5.3 Abuse of Authority or Position

Concerns may be raised regarding:

  • abuse of organizational authority;
  • coercion;
  • serious conflicts of interest;
  • favoritism or nepotism;
  • improper interference with organizational decisions; or
  • using an organizational position for improper personal benefit.

5.4 Serious Ethical or Professional Misconduct

Examples include:

  • deliberate falsification of reports;
  • serious misrepresentation of project results;
  • fabrication or manipulation of research data;
  • plagiarism or research misconduct;
  • deliberate concealment of material information;
  • falsification of beneficiary or monitoring data; and
  • serious violations of organizational policies.

5.5 Safeguarding and Abuse

Concerns involving serious misconduct affecting children, vulnerable people, community members, staff, volunteers, or other participants may be reported, including:

  • exploitation;
  • abuse;
  • harassment;
  • sexual exploitation or abuse;
  • sexual harassment;
  • serious discriminatory conduct;
  • threatening or coercive behavior; and
  • other serious safeguarding concerns.

Where a concern specifically concerns safeguarding, BNF’s Safeguarding Policy and applicable reporting procedures should also be followed.

5.6 Environmental and Social Concerns

Whistleblowing may also concern serious environmental or social risks arising from BNF activities, including:

  • deliberate environmental harm;
  • unauthorized destruction of sensitive habitats;
  • serious biodiversity impacts;
  • concealment of environmental incidents;
  • serious community harm;
  • manipulation of environmental monitoring results; or
  • deliberate failure to implement agreed safeguards.

6. Who Can Make a Report?

A concern may be reported by any person who has reasonable grounds to believe that wrongdoing has occurred, is occurring, or may occur. This may include:

  • BNF personnel;
  • former personnel;
  • volunteers;
  • interns;
  • consultants;
  • contractors;
  • researchers;
  • community members;
  • beneficiaries;
  • partner organizations;
  • suppliers;
  • donors or funding representatives; and
  • members of the public.

A person does not have to prove wrongdoing before making a report. However, reports should be based on genuine concerns rather than knowingly false allegations.

7. Good-Faith Reporting

BNF encourages reporting where a person has reasonable grounds for concern. A good-faith report may be made even when the information later proves to be incomplete or the concern is not substantiated. BNF will not take adverse action against a person simply because a good-faith report is ultimately found to be unsubstantiated. However, deliberately fabricated, malicious, or knowingly false allegations may constitute misconduct and may be subject to appropriate action.

8. Reporting Channels

Concerns should be raised through an appropriate BNF reporting channel. Reports may be submitted through:

Whistleblower/Integrity Email: info@bdnature.org

Complaints & Feedback Email: info@bdnature.org

Written Submission: Executive Director, Bangladesh Nature Foundation

Postal Address: Sayman Road, Cox’s Bazar-4700, Bangladesh

Where the concern involves the Executive Director or another person responsible for receiving reports, the whistleblower should use an alternative reporting route through the appropriate senior governance authority, including the Executive Committee or another designated independent authority. BNF may establish additional confidential reporting mechanisms where appropriate.

9. Anonymous Reports

BNF may accept anonymous reports. A person may choose not to disclose their identity where they reasonably believe that anonymity is necessary for their protection or for another legitimate reason. Anonymous reports should contain as much useful information as possible, including:

  • what happened;
  • when and where it occurred;
  • persons or organizations involved;
  • available evidence or supporting documents;
  • witnesses, where known; and
  • any immediate risk to people, resources, or the environment.

Where anonymity prevents BNF from seeking clarification or conducting a complete investigation, the limitations may be explained in the final assessment.

10. Confidentiality

BNF will treat whistleblower reports as confidential and will limit access to information to persons who have a legitimate need to know. The identity of a whistleblower will not ordinarily be disclosed unnecessarily. However, confidentiality cannot always be guaranteed where disclosure is required for:

  • a fair investigation;
  • legal or regulatory requirements;
  • donor requirements;
  • safeguarding or immediate safety considerations;
  • protection of another person; or
  • other legitimate organizational purposes.

Where reasonably practicable, BNF will take appropriate steps to protect the identity of the reporting person.

11. Protection against Retaliation

BNF prohibits retaliation against a person who makes a genuine report in good faith or assists with an authorized investigation. Retaliation may include:

  • dismissal or unfair disciplinary action;
  • threats or intimidation;
  • harassment;
  • discrimination;
  • exclusion from legitimate work activities;
  • unjustified reduction of responsibilities;
  • adverse treatment;
  • threats to employment or contractual relationships;
  • interference with professional opportunities; or
  • other punitive treatment because a person raised or supported a legitimate concern.

Any suspected retaliation should itself be reported and may be treated as a serious violation of this policy. Protection does not prevent BNF from taking legitimate action for unrelated misconduct or legitimate performance, contractual, or organizational reasons, provided such action is not retaliatory.

12. Initial Assessment of Reports

When a concern is received, BNF will conduct an appropriate initial assessment to determine:

  • whether the matter falls within this policy;
  • whether there is an immediate risk to people, assets, funds, communities, or the environment;
  • whether urgent protective measures are required;
  • whether the matter should be referred to another BNF policy or procedure;
  • whether additional information is required; and
  • whether a formal investigation is appropriate.

Reports will be handled proportionately according to their nature, seriousness, available evidence, and potential impact.

13. Investigation

Where an investigation is considered necessary, BNF will seek to ensure that it is conducted fairly and objectively. Depending on the circumstances, an investigation may involve:

  • reviewing financial and administrative records;
  • examining project documentation;
  • interviewing relevant individuals;
  • reviewing procurement and contractual records;
  • examining research or monitoring data;
  • consulting relevant technical personnel;
  • reviewing electronic or documentary evidence; and
  • engaging an appropriately independent investigator where necessary.

Persons accused of wrongdoing should be treated fairly and given an appropriate opportunity to respond to relevant allegations, subject to confidentiality, safeguarding, evidence-preservation, and other legitimate considerations. A person who is the subject of a report should not control or improperly influence the investigation of that report.

14. Conflicts of Interest in Investigations

Any person responsible for assessing or investigating a report must disclose a relevant conflict of interest. A person should not participate in an investigation where they:

  • are directly involved in the allegation;
  • have a personal or financial interest in the outcome;
  • have a close relationship with a relevant party; or
  • may reasonably be perceived as unable to act impartially.

BNF may appoint another qualified person or an independent investigator where necessary.

15. Immediate Risks and Protective Measures

Where a report identifies an immediate or serious risk to a person, community, organizational asset, project, or environment, BNF may take appropriate interim measures. These may include:

  • protecting affected persons;
  • restricting access to funds, records, systems, or assets;
  • separating individuals from relevant duties;
  • preserving evidence;
  • suspending a transaction or activity pending review;
  • strengthening project controls; or
  • referring the matter to an appropriate authority where required.

Interim measures will not automatically constitute a finding of wrongdoing.

16. Cooperation with Investigations

All relevant BNF personnel and associated persons are expected to cooperate appropriately with authorized investigations. Individuals should:

  • provide truthful information;
  • preserve relevant records;
  • avoid destroying or altering evidence;
  • maintain confidentiality where instructed; and
  • avoid interfering with witnesses or investigators.

Obstruction, intimidation, evidence destruction, or deliberate interference with an authorized investigation may constitute misconduct.

17. Outcome and Corrective Action

Following an investigation or assessment, BNF may take appropriate action based on the findings. Depending on the circumstances, this may include:

  • corrective action;
  • strengthening internal controls;
  • recovery of funds or assets;
  • disciplinary action;
  • contractual action;
  • termination of an engagement or partnership;
  • correction of inaccurate records or reports;
  • additional training;
  • project-level safeguards;
  • notification to relevant donors or authorities where appropriate; or
  • other lawful and proportionate measures.

Where wrongdoing is not substantiated, BNF may close the matter while retaining appropriate records of the assessment.

18. Protection of Evidence and Records

Relevant records associated with whistleblower reports will be handled securely. BNF may maintain records of:

  • reports received;
  • assessment decisions;
  • investigation activities;
  • evidence;
  • findings;
  • corrective actions; and
  • follow-up monitoring.

Records will be retained and accessed according to BNF’s applicable record-management, confidentiality, privacy, and legal requirements.

19. Whistleblowing and External Authorities

BNF encourages concerns to be raised internally where appropriate so that the organization has an opportunity to assess and address them. However, this policy does not prevent a person from contacting an appropriate government, regulatory, law-enforcement, safeguarding, or other competent authority where they reasonably believe that external reporting is necessary or appropriate. Nothing in this policy is intended to restrict any lawful right to make a report to a competent authority.

20. No Retaliation for Participation in an Investigation

Protection under this policy also extends, where appropriate, to persons who:

  • provide information during an investigation;
  • act as witnesses;
  • assist with evidence collection;
  • provide technical advice; or
  • otherwise participate honestly in an authorized review.

BNF will seek to prevent intimidation, retaliation, or interference against such individuals.

21. Responsibilities

General Committee and Executive Committee

The governing bodies are responsible for providing appropriate oversight and supporting a culture of accountability and integrity.

Executive Director

The Executive Director is responsible for ensuring that appropriate systems exist for receiving, assessing, escalating, and addressing whistleblower concerns, subject to the governance arrangements of BNF.

Managers and Supervisors

Managers and supervisors should:

  • take concerns seriously;
  • avoid suppressing legitimate reports;
  • protect confidentiality;
  • escalate serious matters appropriately; and
  • avoid retaliation or conflicts of interest.

All Personnel

All BNF personnel are expected to:

  • act honestly and responsibly;
  • report serious suspected wrongdoing;
  • cooperate with legitimate investigations;
  • preserve relevant evidence; and
  • respect confidentiality.

22. Relationship with Other BNF Policies

This policy should be read together with BNF’s other organizational policies, including:

  • Anti-Fraud and Anti-Corruption Policy;
  • Complaints & Feedback Policy;
  • Conflict of Interest Policy;
  • Safeguarding Policy;
  • Environmental & Social Safeguards Policy;
  • Research Ethics and Research Integrity policies;
  • Code of Conduct;
  • Gender Equality and Non-Discrimination Policy; and
  • Privacy Policy.

Where a concern falls specifically under another reporting mechanism, BNF may coordinate the relevant procedures to avoid duplication and ensure appropriate handling.

23. Accessibility of the Whistleblower Mechanism

BNF aims to make its reporting mechanisms accessible to staff, communities, beneficiaries, partners, and other stakeholders. Where appropriate, BNF may consider:

  • language and literacy barriers;
  • disability-related accessibility needs;
  • remote or field locations;
  • gender-related barriers;
  • concerns about power differences;
  • digital access limitations; and
  • the need for confidential reporting.

No person should be disadvantaged merely because they require a reasonable alternative method for submitting a concern.

24. Monitoring and Review

BNF will periodically review the implementation and effectiveness of this policy. The review may consider:

  • the number and types of concerns received;
  • response and investigation processes;
  • protection against retaliation;
  • recurring risks;
  • internal-control weaknesses;
  • lessons learned;
  • stakeholder feedback; and
  • changes in organizational activities or requirements.

Lessons learned may be used to strengthen BNF’s governance, financial controls, project management, safeguarding, and accountability systems.

25. Commitment to Whistleblower Protection

BNF recognizes that responsible whistleblowing can help identify risks, prevent misconduct, protect communities and natural resources, safeguard organizational funds, and strengthen institutional accountability. BNF therefore encourages genuine concerns to be raised responsibly and is committed to handling such concerns with appropriate confidentiality, fairness, impartiality, and respect. No person should be discouraged from raising a legitimate concern through threats, intimidation, retaliation, or improper pressure. BNF will continue to strengthen its organizational systems so that concerns can be raised, assessed, and addressed in a responsible manner.

26. Contact

Bangladesh Nature Foundation (BNF)

Sayman Road, Cox’s Bazar-4700, Bangladesh

Whistleblower/Integrity Reporting: info@bdnature.org

Complaints & Feedback: info@bdnature.org

Website: https://bdnature.org/

For urgent threats to life, safety, or the environment, individuals should contact the appropriate emergency or competent authority where necessary.

Bangladesh Nature Foundation (BNF) is committed to integrity, accountability, transparency, responsible stewardship, protection of people and communities, and conservation of Bangladesh’s natural heritage. This policy forms part of BNF’s broader governance and accountability framework.