A whistleblower channel for a small nonprofit
A feedback tool is one part of a reporting process. Start with a written policy that tells staff and volunteers where to raise concerns, who will review them, and how to report concerns about leadership.
What Form 990 asks about a written policy
Form 990 Part VI, Section B, line 13 asks whether the organization had a written whistleblower policy. The current IRS instructions describe a policy that invites credible concerns about illegal conduct or breaches of organizational policies, names recipients, and protects reporters against retaliation. Section B explains when an organization-wide adopted policy supports a yes answer. IRS Form 990 instructions, Part VI, Section B and lines 13–14.
This governance question is about the policy, not a certification of a software product. TellSafe does not establish compliance with any legal or regulatory requirement. This guide is not legal advice; ask a qualified adviser to review your policy and filing circumstances.
What a small nonprofit needs
Use these as practical planning choices, not a statement of legal requirements. Put the process in writing before sharing a reporting link.
- A written policy: explain which concerns it covers, who reviews them, and how follow-up works.
- More than one reporting route: offer a named person and a separate phone, in-person or written contact alongside an anonymous channel.
- A route around leadership: name an independent board contact or outside reviewer for concerns about the executive director, board chair or usual recipient. Check who can actually access each inbox; a different contact name alone does not create independence.
- No retaliation: prohibit retaliation for good-faith reports, explain where to report it, and assign someone independent to review those concerns.
Where an anonymous two-way channel fits
A private channel gives someone a way to raise a concern and clarify it without showing their address to organizers. TellSafe's Anonymous Relay processes an email address for delivery while hiding it from organizers; message details may still identify the person. Plain Anonymous submissions cannot receive replies. See two-way anonymous replies and the privacy model.
Publish who reads the channel, review hours, a realistic update schedule and an alternative contact. Limit access to appropriate reviewers and explain confidentiality limits. The organization remains responsible for assessing concerns and arranging qualified help.
How this differs from a hotline vendor
TellSafe provides a web feedback channel and anonymous relay, rather than staffed telephone intake or an outsourced investigation. If you need those services, ask a hotline vendor what its contract includes: intake hours, languages, independent routing, case handling, record access and response responsibilities. Compare those services with what your nonprofit can staff itself. See the NAVEX comparison.
Short sample policy outline
This original outline is a starting point to adapt with a qualified adviser, not a ready-made legal policy. Replace every bracket with arrangements you can provide.
- Purpose and scope: staff and volunteers may raise good-faith concerns about [misconduct and policy violations covered].
- Reporting routes: contact [primary recipient/contact], [separate backup/contact], or [anonymous link and privacy explanation].
- Leadership and conflicts: send concerns about a recipient or leader directly to [independent reviewer/contact]; restrict implicated people's access.
- No retaliation: prohibit retaliation for good-faith reporting; report suspected retaliation to [independent contact].
- Review and updates: [responsible role] checks reports during [hours], acknowledges when a reply route exists, assesses next steps and shares updates at [interval].
- Records and privacy: explain [authorized access, necessary disclosures, retention arrangements and confidentiality limits].
- Other reporting: identify [urgent help and applicable external reporting routes reviewed by your adviser]; internal reporting does not replace required reporting.
Sources and scope
The current IRS Form 990 instructions (2025) were checked live for the governance discussion. The workflow and outline are planning suggestions, not legal advice.