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Whistleblower Policy

Capital for Good (CfG) and the Girls First Fund (GFF) require that Girls First Fund Board Committee  members, staff, consultants, and grantees observe high standards of professional and personal ethics  and that they comply with all applicable laws and regulations as they fulfill their duties and  responsibilities. Girls First Fund is committed to responding to reports of misconduct that are received and using them to correct inappropriate actions; improve the processes and operations of the fund; and  ensure safety, integrity, and justice within our work and the way we work.  


The purpose of this policy is to encourage and enable those with serious concerns about the Girls First Fund to safely raise these concerns so that they can be addressed and an attempt to correct inappropriate conduct can be made. 


This policy may be used by anyone to raise concerns about misconduct or wrongdoing when believed to be undertaken by any individuals working under contract or agreement with the Girls First Fund. This includes board members, full- and part-time employees, consultants, interns, volunteers, and grantee partners. 


The Girls First Fund needs to know about risks related to its funding. This may include violations of domestic or international law, corruption or fraud, acts of a dangerous or criminal nature, instances of sexual harassment or misconduct, or any other serious risks to the operations of the fund or the well being of individuals associated with the Girls First Fund or Girls First Fund-funded work. A list of examples of misconduct is provided in Annex 1. Please refer to Girls First Fund’s Safeguarding Policy for more information specific to safeguarding concerns.

If you have information about a risk or believe that wrongdoing may have occurred, has occurred, or could occur, please make sure it is known by following procedures explained below. Please include as much specific information as possible to enable Girls First Fund to understand your concern, including include where and when the incident occurred, names and titles of the individuals involved, and as much other detail as you can provide.

Anyone filing a written complaint should act in good faith and have reasonable grounds for believing the information disclosed indicates misconduct or wrongdoing. Any allegations that prove not to be true will be dismissed. Any allegations that are baseless or made maliciously or knowingly to be false will be dismissed. 


The Girls First Fund seeks to address problems before or as soon as they arise. For that reason, it is important that GFF is advised of a concern quickly so that it can undertake a fair, impartial, and prompt examination of matters brought to its attention. However, GFF recognizes that extenuating circumstances and the nature of the misconduct may result in delayed reporting. 


Girls First Fund team members have the responsibility to treat sensitive information with confidentiality and to protect your identity. It may be impossible to resolve a concern or conduct an adequate investigation without revealing your identity, for example if you are the only person who is privy to the information. In such a case, this will be discussed with you and your identity will not be intentionally revealed without prior written permission, unless required to do so by law. 

You can report anonymously, without disclosing your identity. Because it is impossible to seek additional information from an anonymous report, it is essential that such reports contain as much specific information as possible. 

No retaliation 

GFF has a strict no retaliation policy and will make all possible efforts to ensure that no GFF-contracted or -related individual retaliates against you as a result of the report you have made. Any GFF-contracted or -related individual who retaliates against someone that has reported a concern under this policy, or has cooperated in the investigation of a concern, is subject to discipline. Instances of retaliation may also be a violation of employment and/or contract, including immediate suspension or termination. 


If you have a concern, you are encouraged to share detailed information using one of the modes outlined below. The email account listed below and mail received in the United States are monitored by the GFF Senior Operations Officer. All information received is confidential as mentioned above. Reports will be reviewed by the GFF Director and, where needed, additional members of the GFF team and Capital for Good. These recipients have the duty to ensure appropriate follow-up as outlined below.



Capital for Good 

ATTN: Girls First Fund Whistleblowing/Safeguarding 

1536 E Lancaster Avenue 

Paoli, PA USA 19301 

If you are a grantee partner, you are encouraged to raise your concerns first with your primary Girls First Fund contact. If your concern is related to your primary Girls First Fund contact, you are encouraged to utilize one of the forms of communication listed above. 

External reporting 

Given the nature of your concern, the GFF team may discuss the option for you to also report to relevant local authorities. This may be the first course of action when failure to do so will result in physical harm to yourself or another individual or is mandated by national law. Please note that while the Girls First Fund needs to understand risks associated with its funding, reporting such instances to Girls First Fund does not negate the need for those reporting to adhere to national laws and guidelines. 


  1. You will receive an initial response to your report within five working days after receipt of the information. An early response may be limited to giving you an idea of next steps and a probable timeline.
  2. Within 30 working days you will receive a follow-up response to your concern and an outline of the way forward. Should an investigation be necessary, any related, reasonable cost will be the responsibility of GFF. 
  3. Whenever possible, you will receive feedback on the outcome of any investigation. Please note, however, that it may not be possible to inform you about the precise actions taken where this would infringe upon the legal rights of another person.

Annex 1: Illustrative list of misconduct 

The list below is not extensive but serves to provide examples of the types of scenarios GFF would like to hear about. 

  • Suspected fraud; fraudulent financial reporting; misappropriation, embezzlement, or misuse of financial resources. 
  • Forgery or alteration of documents; unauthorized alteration or manipulation of computer files to conceal information. 
  • Authorizing or receiving compensation for goods not received or services not performed.
  • Showing undue favor over a contractual matter or to a job applicant; non-disclosure of a conflict of interest in hiring or firing. 
  • Violation of GFF’s safeguarding policy (please refer to GFF’s safeguarding policy for more details). 
  • Using remarks or actions of a sexual nature that are not welcome and are likely to be viewed as personally offensive, including sexual flirtations; unwelcome physical or verbal advances; sexual propositions; verbal abuse of a sexual nature; the display of sexually suggestive objects, cartoons, or pictures; and physical contact of a sexual or particularly personal nature. 
  • Using slurs, negative stereotyping, and threatening, intimidating, or hostile acts that relate to race, color, religion, gender, gender identity, sexual orientation, national origin, age, or disability.
  • Circulating or posting written or graphic material in the workplace that denigrates or shows hostility or aversion toward an individual or group because of race, color, religion, gender, nationality, age, or disability.
  • Discriminating against an employee or potential employee due to a person’s race, color, religion, sex, sexual orientation, national origin, age, physical or mental impairment.
  • Committing a criminal offence. 
  • Disregarding legislation.
  • Other actions that do not respect the dignity and wellbeing of others. 

Note: The Girls First Fund is a fiscally sponsored program of Capital for Good USA, a tax-exempt public charity under Section 501(c)(3) of the Internal Revenue Code. 

Note: When possible and appropriate, the Girls First Fund encourages grantee partners to utilize their own policies and procedures to resolve organizational challenges that arise. However, the Girls First Fund needs to know about risks related to its funding.