TFC Whistle Blower Policy


The Audit Committee of the Board of Directors of the Three Fires Council Boy Scouts of America (the “Council”) has adopted the following policies and procedures for:  (i) the receipt, retention, and treatment of complaints  received by the Council; and (ii) the confidential, anonymous submission by employees of the Council of concerns regarding questionable practices involving unethical or illegal conduct.

Reporting of Concerns or Complaints

Taking action to prevent problems is part of the Boy Scouts’ and Council’s culture.  If you observe possible unethical or illegal conduct, you are encouraged to report your concerns.  Employees and others involved with the Council are urged to come forward with any such information, regardless of the identity or position of the suspected/perceived offender.

Employees and others may choose any of the following modes of communicating concerns regarding unethical or illegal conduct:

  1. If complaint is about another employee or volunteer, discuss with Supervisor.
  2. If complaint is about Supervisor, discuss with Scout Executive.
  3. If complaint is about Scout Executive, contact Area Director.
  4. Contact Joe Wiltrout, Scout Executive of the Council, at the contact information below or send either a signed or anonymous written report to the Chairman of the Council’s Audit Committee or Deputy Regional Director.


            Joe Wiltrout

            Scout Executive

            Three Fires Council, Boy Scouts of America

            415 North Second Street

            St. Charles, IL  60174

            Fax:  630-584-8598



            Jerry DeVault

            Chairman, Audit Committee

            Three Fires Council, Boy Scouts of America

            Fax:  866-338-2483



            Deputy Regional Director 

            Fred Wallace

            Boy Scouts of America



Scope of Matters Covered by These Procedures

These procedures relate to employee complaints relating to any conduct that is unethical, illegal, or is in violation of BSA or Council rules, regulations or procedures.  Unethical or illegal conduct may include:

  • An unlawful act whether civil or criminal;
  • Unprofessional conduct or conduct that violates the principals of the Boy Scouts;
  • Abuse of power or authority for an unauthorized or ulterior purpose;
  • Dangerous practice likely to cause physical harm or damage to any person or property;
  • Unfair discrimination in the course of the employment or provision of services;
  • Fraud or deliberate error in the preparation, evaluation, review, or audit of any financial or membership statement  of the Boy Scouts;
  • Fraud or deliberate error in the recording and maintaining of financial or membership records of the Boy Scouts;
  • Deficiencies in or noncompliance with the Boy Scouts’ internal accounting controls;
  • Deviations from full and fair reporting of the Boy Scouts’ financial and membership conditions.

This list is not definitive, but is intended to give an indication of the kind of conduct, which might be considered unethical or illegal.


The Council will treat all communications under this Policy in as confidential a manner as possible, except to the extent necessary (1) to conduct a complete and fair investigation, or (2) for reviews of  Council operations by the Council’s Board of Directors, its Audit Committee, the Council’s independent public accounts, accountants,  and/or the National Council.

Treatment of Complaint; Non-Retaliation

Complaints received pursuant to this policy will be reviewed under Audit Committee direction and oversight by our outside counsel, internal auditors or such other person as the Audit Committee determines to be appropriate.

Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee.

Any individual, who in good faith reports any concerns pursuant to this policy, even if the report is mistaken, or who assists in the investigation of a reported complaint will be protected by the Council from any adverse employment action that is based on the complaint.  Retaliation in any form against these individuals will not be tolerated.  Any act of retaliation should be reported immediately and will be dealt with appropriately.  However, any false accusations made knowingly may constitute misconduct for which disciplinary action may be imposed.

Specifically, we will not discharge, demote, suspend, threaten, harass, or in any other manner discriminate or retaliate against any employee in the terms and conditions of their employment because of any lawful act done by that employee in good faith to either (1) provide information, cause information to be provided, or otherwise assist in any investigation regarding any conduct which the employee reasonably believes constitutes a violation or potential violation of any law, rule, or regulation, or (2) in good faith file, cause to be filed, testify, participate in, or otherwise assist in a proceeding filed or, to the employee’s knowledge, about to be filed relating to an alleged violation of any such law, rule, or regulation.

Reporting and Retention of Complaints and Investigations

The Council will maintain a log of all complaints, tracking their receipt, investigation, and resolution and shall prepare a periodic summary report thereof for the Audit Committee.  Copies of complaints and such log will be maintained in accordance with the Council’s document retention policy.