Anti-Fraud and
Whistleblower Policy

August 19, 2023

Effective Date: July 19, 2025

Approved by: Board of Directors

Review Cycle:  Annually
Applies to: All staff, volunteers, board members, Key Volunteers, program participants, contractors, and collaborators

1. Purpose

Infinite Wave Foundation is committed to the highest standards of ethical conduct, accountability, and transparency. This   Anti-Fraud and Whistleblower Policy outlines the Foundation’s stance against fraud and provides a clear process for individuals to report concerns regarding fraud, misconduct, or unethical behavior in a safe and confidential manner.

2. Scope

This policy applies to all directors, officers, employees, volunteers, contractors, consultants, and any individual or entity engaged in business with Infinite Wave Foundation.

3. Definition of Fraud

• Theft of funds, supplies, or other assets

• Forgery or alteration of document or records

• Misinterpretation of facts

• Bribery of corruption

• Conflict of Interest not disclosed

• Misuse or misappropriation of charitable assets

• Any illegal or unethical act affecting the integrity of the Foundation

4. Commitment to Integrity and Prevention

Infinite Wave Foundation is committed to:

• Preventing fraud through effective internal controls, policies, and procedures

• Promoting awareness of fraud risks

• Detecting fraud through audits, reviews, and accountability systems

• Responding swiftly and appropriately to suspected or actual fraud

5. Whistleblower Policy

1. Reporting Concerns
   Anyone who becomes aware of actual or suspected fraud, unethical behavior, or misconduct is encouraged to report their concerns promptly. Reports may be made anonymously and will be treated confidentially to the extent possible.

Concerns can be reported to:

• The President – Renardo Edwards: renardo@infinitewavefoundation.com

• The Vice President – Jamie Aragon-Edwards-  jaimie@infinitewavefoundation.com

• Or by email to: whistleblower@infinitewavefoundation.com

2. Protection Against Retaliation
   No individual who in good faith reports concerns or cooperates in an investigation shall suffer retaliation, harassment, discrimination, or adverse consequences. Retaliation is grounds for disciplinary action, up to and including dismissal or termination of relationship with the Foundation.

6. Investigation Process

• All allegations will be reviewed promptly and investigated fairly and objectively.

• The investigation may be conducted internally or by external parties as determined by the Board.

• Findings will be documented, and appropriate corrective action will be taken

• Law enforcement may be notified where criminal activity is suspected

7. Responsibilities

Board of Directors:
Provides oversight and ensures proper investigation of fraud and whistleblower reports.

Executive Director:
Implements internal controls and reports fraud risks or occurrences to the Board.

Staff and Volunteers:
Expected to act with integrity and report suspected fraudulent or unethical activity.

8. Confidentiality

All reports and investigation will be handled with discretion. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate investigation and comply with applicable laws.

9. Review and Amendments

This Policy shall be reviewed at least every two years or as needed to reflect changes in laws, best practices, or organizational needs. Amendments require approval by the Board of Directors.