Guidance on Obligations of Elected Leaders to Share Critical Information Related to Code of Conduct

This guidance is intended to assist leaders of the Federation in dealing with sensitive information regarding a code of conduct violation that is disclosed by an individual who does not want to report the incident through the Federation’s code of conduct themselves. This guidance is intended to help all responsible leaders understand that, while survivors have a right to choose not to disclose their stories, leaders of the Federation have an obligation to responsibly share information in order to maintain a high level of trust, safety, and accountability within our movement. This guidance is intended to support leaders in keeping the survivor’s personally identifiable information confidential, while ensuring that the organization collects data points that might help identify patterns of behavior among members, which will need to be formally addressed. Please note that nothing in this document is intended to address or supersede mandatory reporting requirements that responsible leaders may have related to the participation of minors in Federation programs. While this document addresses instances where an individual survivor has faced harmful circumstances that they may feel uncomfortable disclosing, this guidance can be applied to any violation of the code of conduct where an individual may provide information to a leader but feel uncomfortable being revealed as the individual who reported the incident.

Responsible Leader: National board members, affiliate board members, local chapter or division board members, national division board members, and Federation employees, including employees of affiliated training centers, are considered responsible leaders and, thus, should understand and be prepared to follow the below guidance.

Guidance:

•    A responsible leader shall follow the process below if such individual becomes aware that a member, NFB employee, contractor, or other individual or group of individuals participating in an NFB event or in any training center program may have violated the Code of Conduct. 

•    The responsible leader should talk through various options available to the person providing the information about the incident (survivor), including but not limited to following the code of conduct process to report the incident, reporting to law enforcement, etc. The responsible leader should remind the person of the responsible leader’s obligations as outlined in this guidance as early as possible for full transparency. If the person making the report does not want to use the code of conduct process and wants their name to remain anonymous, the responsible leader will use the Federation’s online code of conduct complaint form to report as much detail as possible without providing information that would personally identify the survivor. A report can also be submitted by sending an email to [email protected] .

•    The complaint form should be completed within one week of the responsible leader learning about the information whenever possible, as long as the survivor who shared the incident has definitively decided not to proceed with the formal code of conduct process. If the one-week deadline is missed, the responsible leader still has an obligation to share the information. The responsible leader should always give the person who reported the information to them advance notice before disclosing the information, even anonymously, through the code of conduct process.

•    The responsible leader’s report shall identify information about the alleged transgressor but not the person who brought the information forward. Details will be included about the kind of misconduct that occurred and as much of the narrative as possible without revealing the identity of the person who brought the information to the responsible leader.

•    The completed complaint form will be routed through the normal process for code of conduct complaints, and the data will be tracked. Based on the detail provided, the Federation’s external investigator may follow up to gather additional information. If engaged, the external investigator will inform the President of their findings. 

•    Based upon the findings of the external investigator, recommendations will be made to the President for immediate actions to be taken.