Code of Conduct + Whistleblower Protection Policy / Procedure

 

  • The Kittery Art Association

    Code of Conduct
    Adopted by The Kittery Art Association Board on 3/12/2026

    The Kittery Art Association (“KAA”) envisions a vibrant inclusive cultural hub that values integrity, honesty, openness, and transparency in all dealings. In this spirit, this Code is a shared statement of our commitments to uphold our ideals as outlined in the KAA Vision Statement.

    Our Code of Conduct establishes expectations for the behavior of all persons associated with the Kittery Art Association (KAA), including Board Members, Member Artists, Employees, Independent Contractors and Volunteers (hereafter referred to as “KAA associates”) regarding their interactions with other KAA associates and the general public when serving as a representative of the KAA. All KAA associates are expected to comply with all local and federal laws and regulations, and our Code of Conduct. Given the complexity of ethical questions that may arise this Code can serve only as a general guide. Confronted with ethically ambiguous situations, KAA associates should keep in mind the vision and mission of the Kittery Art Association.

    1.) Respect for Others

    KAA associates are expected to foster a respectful and collaborative environment and avoid offending or disrupting KAA activities. KAA associates are expected to treat all other KAA associates and the general public with respect, courtesy, and dignity. Harassment or disparagement based on someone’s race, gender, gender expression, sexual orientation, physical ability, neurodiversity, religion, body type, country of origin, age, or socioeconomic background is prohibited. Prohibited its include, but are not limited to, verbal harassment (epithets, derogatory or degrading statements, slurs), physical harassment (assault, physical interference with normal work or involvement), and innuendo. Any conduct that creates an intimidating, offensive, or hostile environment is prohibited, even if such conduct occurs off of KAA property or outside of normal hours so long as it relates to the KAA. We expect KAA associates to be ethical and responsible when dealing with our finances, art exhibited by the KAA, our partnerships, and public image.

    2.) Protection of KAA Property

    All KAA associates should treat KAA property, whether tangible or intangible, as well as artwork consigned to the KAA, with respect and care and not take any action that could harm KAA’s reputation. KAA associates should protect KAA property from damage and vandalism whenever possible. Misuse or frivolous use of KAA assets is prohibited. KAA associates should respect all KAA intangible property, including trademarks and other KAA information and reports, and use them only to complete their official KAA duties. Confidential information related to the affairs of KAA shall not be shared, copied, reproduced, or otherwise disclosed, and only information deemed for public knowledge may be shared externally.

    3.) Integrity, Ethics, and Conflicts of Interest

    KAA associates are expected to represent KAA with integrity and professionalism in all KAA activities and act in the best interest of the KAA. They must avoid any personal, financial, or other interests that might hinder their capability or willingness to perform their responsibilities at KAA. KAA associates are prohibited from accepting gifts, gratuities, service, or any item of value related to their role at KAA, which could be interpreted as an inducement to provide special treatment.

    4.) Job Duties and Authority

    KAA associates should fulfill their duties with integrity and respect toward customers, stakeholders, and the community and not abuse their authority. KAA associates are expected to complete their duties in a timely manner. Collaboration is encouraged throughout the organization. Absenteeism, tardiness, and leaving early hurts our reputation and effectiveness.

    5.) Communication

    Adherence to our Code of Conduct pertains to all KAA associates throughout all types of communications and correspondence, whether it be verbal, email, or other media, or in any public forum. KAA associates shall support KAA’s position and policies in all communications with other associates and the public. KAA associates must be open to communication from their colleagues, team members, and other KAA associates. KAA has an open door policy.

    6.) Resolution of Issues

    The KAA is committed to having every KAA associate and member of the public receive fair and impartial treatment, but recognizes that occasionally conflicts, misunderstandings, or problems may arise. Although most of these can and should be addressed directly on an informal basis, we have established a process to resolve any issues that cannot be resolved informally and independently.


    Process of Investigation of Complaints

    a.) Should an associate feel there has been a violation of this Cod elf Conduct, they may follow the procedure outlined in the Whistleblower Policy. This policy is posted on the KAA website under the “About KAA” section.

    b.) KAA associates should respectfully inform the person who is the subject of the complaint.

    c.) The KAA Board will promptly conduct an iniquity into any complaint made under the KAA Whistleblower Protection Policy. This procedure is described in the Whistleblower Procedure. It is expected that all parties will operate in good faith. Any KAA associate who is determined, after an inquiry, to have engaged in conduct that is in violation of this Code of Conduct shall be subject to discipline, up to and including suspension and termination of employment, membership, or volunteer assignment. All complaints shall be treated confidentially, to the extend possible. KAA shall not retaliate against any KAA associate or member of the public who files a complaint in good faith, or who participates in good faith, in an inquiry of a violation of this Code of Conduct.

    Any questions about this document should be directed to KAA’s President or a member of the KAA Board of Directors.

    info@kitteryartassociation.org

    Code of Conduct Policy adopted by the KAA Board of Directors on: March 12, 2026

  • The Kittery Art Association
    Whistleblower Protection Policy
    Adopted: January 15, 2026
    Revised: March 12, 2026

    Introduction

    The Kittery Art Association (KAA) envisions a vibrant inclusive cultural hub that values integrity, honesty, openness, and transparency in all dealings. The KAA adopts the following Whistleblower Protection Policy in order to strengthen its existing policies and procedures, maintain and exemplify “best practices,” encourage and enable Board Members, Member Artists, Employees, Independent Contractors, and Volunteers (hereafter referred to as “KAA associates) to raise Concerns within the KAA for inquiry and appropriate action, and comply with applicable laws* and regulations.

    The Whistleblower Policy

    The KAA is committed to facilitating open and honest communications relevant to its governance, finances, and compliance with all applicable laws and regulations, including safety regulations. The KAA requires KAA associates to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. KAA associates must practice honesty and integrity in fulfilling their responsibilities, adhere to the KAA Code of Conduct, and comply with all applicable laws and regulations.

    This Whistleblower Protection Policy (“the Whistleblower Policy”) reflects the practices and principles of behavior that support this commitment. It is important that the KAA and its Board be apprised about unlawful or improper workplace behavior including, but not limited to, any of the following conduct:

    • Theft;

    • Financial or safety reporting which is fraudulent, intentionally misleading or negligent in any manner;

    • Improper or undocumented financial transactions, either intentionally or unintentionally;

    • Forgery or alternation of documents;

    • Unauthorized alteration or manipulation of computer files;

    • Improper destruction of records;

    • Improper use of the KAA assets, including, but not limited to its property, facilities, funds, supplies, and other assets;

    • Improper access and or use of confidential information

    • Authorizing or receiving compensation for goods not received or services not performed;

    • Violations of the KAA’s Whistleblower Policy;

    • Any other improper occurrence regarding cash, financial procedures, safety or reporting;

    • Any abuse of, or discrimination against a KAA member; and

    • a failure by the KAA to provide reasonable accommodation for disability or religious belief

    • Violation of the KAA Code of Conduct Policy.

    We request the assistance of any KAA associate who has a reasonable belief or suspicion about any improper transaction or unethical behavior. The KAA values this input, and each associate should feel free to raise issues of concern in good faith, without feat of retaliation. KAA associates shall not be disciplined, expelled, or be retaliated against in any way for asking questions or reporting concerns.

    The KAA will conduct a process of inquiry of any possible fraudulent or dishonest use or misuse of the KAA’s resources, or abuse, discrimination era. Failure to provide reasonable accommodation by KAA associates according to the Whistleblower Procedure. The KAA will take appropriate action against anyone found to have engaged in fraudulent, dishonest, abusive or discriminatory conduct, including expulsion from the KAA, termination, or civil or criminal prosecution, when warranted.

    Therefore, all KAA associates are encouraged to report suspected fraudulent, abusive, discriminatory, or unethical conduct (i.e., to act as a “whistleblower”), pursuant to the procedures set out below.

    Whistleblower Procedure

    The KAA is committed to protecting the confidentiality of all concerned parties. To that end, any reported Concerns shall follow the process explained in the Whistleblower Procedure. All reported Concerns shall be forwarded to the Board and resolved as the Procedure outlines.

    No Retaliation

    No KAA associate who, in good faith, reports a Cancer shall be subject to retaliation or expulsion. Whistleblowers who believe that they have been retaliated against may file a written complaint with the Board. Moreover, a volunteer or member who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including termination, dismissal from the volunteer position or expulsion from the KAA. This protection from retaliation does not prohibit the Operations manager from acting in the usual scope of their duties and based on valid safety-related factors.

    Acting in Good Faith

    Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, unethical behavior, or a violation of the KAA’s policies. The act of making allegations that prove to but unsubstantiated, and/or that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, shall be viewed as a serious offense and may result in discipline, up to and including termination, dismissal from the volunteer position or expulsion from membership. Such conduct may also give rise to other actions, including civil lawsuits.


    Rights and Responsibilities of KAA Associates

    Privacy and Confidentiality

    The KAA will use its best efforts to protect whistleblowers privacy and confidentiality. All complaints by whistleblowers will be handled with sensitivity and discretion to the extend allowed by the circumstances and the law. Generally, this practice means that whistleblower concert will only be shared with those who have a need to know in order to conduct an effective inquiry. Should disciplinary or legal action be taken against a person or persons as as result of a whistleblower complaint, such person(s) may also have a right to know the identity of the whistleblower.

    Notification

    This Whistleblower Policy is to be communicated to all new associates. In addition, each year, after the annual election of the officers and directors, the Secretary will have the responsibility of updating the contact information below for each of these individuals.


    Contact Information:

    Whistleblower Contact 1: Angelique Luro
    Email: aluro@me.com

    Whistleblower Contact 2: Ernie D’Angelo
    Email: ernie@kitterypoint.com

    Whistleblower Contact 3: Michael Kelso
    Email: michaelkelso.kaa@gmail.com


    *Non-profit organizations are required by federal law to adopt a Whistleblower Protection Policy (Public Company Accounting Reform and Investor Protection Act of 2002, “Sarbanes-Oxley”). This is one of two requirements of Sarbanes-Oxley that apply to non-profits, which are otherwise not subject to that federal legislation.

  • Kittery Art Association
    Whistleblower Procedure
    Adopted: March 12, 2026

    1.) Purpose

    The purpose of this Whistleblower Procedure is to support employees, volunteers, artists, contractors, and board members of The Kittery Art Association, hereafter referred to as “KAA,” to report in good faith any suspected misconduct, illegal activity, financial impropriety, or violations or organizational policies. This procedure is designed to protect individuals who report concerns from retaliation and to ensure reports are handled responsibly and confidentially.

    2.) Reporting a Concern

    Individuals are encouraged to report concerns as soon as possible. Reports may be made through any of the following channels:

    Reports shall be submitted in writing. Anonymous reports will be accepted to the extent permitted by law, though providing contact information may assist with the process of inquiry.

    3.) Confidentiality

    All reports shall be handled with sensitivity and description. Information shall be shared only with individuals who need to know in order to conduct a process of investigation and resolve the matter appropriately, consistent with applicable legal requirements.

    4.) Process of Inquiry

    Upon receipt of a report, the designated recipient shall acknowledge the concern as soon as possible, and pass along the information to the appropriate parties.

    An initial assessment shall then be conducted to determine the appropriate course of action, including who should be involved in any inquiry.

    The intended course of action will be presented to the complainant for consent to move forward.

    The subject of the inquiry shall be notified in writing. This notification shall not violate any confidentiality of the complainant without their express consent.

    An inquiry may be carried out by internal leadership, a board committee, or an external advisor, depending on the nature and severity of the concern.

    Findings and recommendations shall be documented and presented to the relevant parties, and appropriate authority (e.g., Gallery manager, Board President, or Board of Directors).

    Corrective action shall be taken when warranted.

    5.) Record keeping

    All whistleblower reports and related investigation records will be retained securely in accordance with the association’s document retention policy and applicable laws.

    6.) Policy Review and Approval

    This Whistleblower Procedure will be reviewed periodically by the Board of Directors and updated as necessary.

    Approved by the Board of Directors on: March 12, 2026