Whistleblower Protection Policy

1. Purpose

The headacheMD for all Foundation (the "Foundation") is committed to the highest standards of legal, ethical, and moral conduct. This Whistleblower Protection Policy is designed to:

• Encourage employees, volunteers, board members, and other stakeholders to report suspected violations of law, policy, or ethical standards;
• Protect individuals who make good faith reports from retaliation;
• Ensure that reports are investigated promptly and thoroughly;
• Comply with applicable federal and state laws regarding whistleblower protection, including the Sarbanes-Oxley Act and other relevant regulations.

2. Scope

This policy applies to all employees, volunteers, board members, contractors, and agents of the Foundation. It covers reports of suspected violations including, but not limited to:

• Violations of federal, state, or local laws or regulations;
• Violations of Foundation policies and procedures;
• Financial improprieties, including fraud, embezzlement, or misuse of Foundation funds;
• Conflicts of interest that have not been properly disclosed;
• Improper payments to or from Foundation officials or employees;
• Violations of HIPAA or other privacy laws;
• Discrimination, harassment, or other violations of equal opportunity laws;
• Unsafe working conditions;
• Any other conduct that could damage the Foundation's reputation or violate its ethical standards.

3. Reporting Procedures

3.1 How to Report

Individuals may report concerns through any of the following channels:

• Direct Reporting: Report to your immediate supervisor, the Executive Director, or any member of the Board of Directors.
• Confidential Email: Send an email to compliance@headacheMD.org
• Written Report: Mail a written report to:
  headacheMD for all Foundation
  Attn: Compliance Officer
  19907 Empress Crossing Ct
  Spring, TX 77379
• Phone: Call (713) 426-3337 and ask to speak with the Compliance Officer or Board President.

3.2 Anonymous Reporting

Reports may be made anonymously. However, anonymous reports may be more difficult to investigate. Individuals are encouraged to provide their contact information so that follow-up questions can be asked and the individual can be informed of the outcome of the investigation.

3.3 What to Include in Your Report

When making a report, please include as much of the following information as possible:

• Description of the suspected violation or concern;
• Names of individuals involved (if known);
• Dates and times of incidents (if applicable);
• Location where the incident occurred;
• Names of witnesses (if any);
• Any documentation or evidence you have;
• Your contact information (unless reporting anonymously).

4. Investigation Procedures

4.1 Receipt of Report

All reports will be received by the Compliance Officer or designated board member. The recipient will:

• Acknowledge receipt of the report (if contact information is provided) within 5 business days;
• Maintain confidentiality to the extent possible;
• Document the report in a secure, confidential file.

4.2 Investigation Process

Upon receipt of a report, the Foundation will:

• Determine whether an investigation is warranted;
• Assign an investigator who is independent and has no conflict of interest;
• Conduct a prompt, thorough, and objective investigation;
• Complete the investigation within 60 days, or notify the reporting party of the need for additional time;
• Document all findings and conclusions;
• Take appropriate corrective action if a violation is found.

4.3 Confidentiality

To the extent possible, the Foundation will maintain the confidentiality of the reporting individual and the subject of the report. However, confidentiality cannot be guaranteed, and disclosures may be necessary:

• To conduct a thorough investigation;
• To comply with legal requirements;
• To protect the rights of the accused;
• To prevent harm to others.

5. Protection Against Retaliation

5.1 Prohibition of Retaliation

The Foundation strictly prohibits any form of retaliation against individuals who, in good faith:

• Report suspected violations;
• Participate in an investigation;
• Refuse to participate in illegal or unethical conduct;
• File a complaint with a government agency.

5.2 What Constitutes Retaliation

Retaliation includes, but is not limited to:

• Termination, demotion, or reduction in pay or benefits;
• Threats, intimidation, or harassment;
• Unfavorable work assignments or changes in job duties;
• Exclusion from meetings or activities;
• Negative performance evaluations;
• Any other adverse action based on the reporting of concerns.

5.3 False Reports

This policy protects individuals who make reports in good faith. Individuals who make false, malicious, or knowingly inaccurate reports may be subject to disciplinary action, up to and including termination of employment or removal from the board.

6. Reporting Suspected Retaliation

If you believe you have been retaliated against for reporting a concern or participating in an investigation, you should immediately report this to:

• The Board President;
• The Compliance Officer;
• Any member of the Board of Directors;
• An external legal counsel or regulatory agency.

Reports of retaliation will be investigated promptly and may result in disciplinary action against those who engaged in retaliation.

7. Corrective Action

If an investigation confirms that a violation has occurred, the Foundation will take appropriate corrective action, which may include:

• Disciplinary action against the violator(s), up to and including termination of employment or removal from the board;
• Corrective measures to prevent future violations;
• Recovery of misused funds or assets;
• Reporting to law enforcement or regulatory agencies when required by law;
• Implementation of additional policies or procedures to prevent recurrence.

8. Communication of Results

To the extent possible and consistent with legal requirements and the need to protect confidentiality, the Foundation will inform the reporting individual of:

• Whether an investigation was conducted;
• Whether a violation was found;
• General information about corrective action taken (without identifying specific individuals or details that could breach confidentiality).

9. External Reporting

Nothing in this policy prevents individuals from reporting suspected violations to:

• Law enforcement agencies;
• Regulatory bodies (such as the IRS, state attorney general, or medical licensing boards);
• Other appropriate government agencies.

Individuals may report to external agencies at any time and are not required to first report internally. However, internal reporting is encouraged as it allows the Foundation to address concerns promptly.

10. Record Keeping

The Foundation will maintain confidential records of all reports, investigations, and outcomes. These records will be retained in accordance with the Foundation's Document Retention and Destruction Policy and applicable legal requirements.

11. Training and Awareness

The Foundation will:

• Provide training on this policy to all employees, volunteers, and board members;
• Make this policy readily available on the Foundation's website and in employee handbooks;
• Periodically remind stakeholders of their rights and responsibilities under this policy.

12. Policy Review

This policy will be reviewed annually by the Board of Directors to ensure it remains effective and compliant with applicable laws. Updates will be made as necessary.

13. Contact Information

For questions about this policy or to report a concern, contact:

headacheMD for all Foundation
Compliance Officer
Email: compliance@headacheMD.org
Phone: (713) 426-3337
Address: 19907 Empress Crossing Ct, Spring, TX 77379