Independence Concerns and Complaints Procedure
Adopted by the Board of Directors · 9 October 2026 · Version 1.0 · Next review: October 2027
Proposed amendment (October 2026). Policy 04 (Whistleblower and Complaints) of the July 2026 Core Governance Policies was written for a charity and is not published. The board will be asked to replace each reference to it in this procedure with the text below, so the protections can be read in full here. Until then, AWARE applies them as written.
- Non-retaliation. No one who raises a concern in good faith will be dismissed, disciplined, lose a contract, engagement or session, or be treated less favourably because they raised it. Retaliation is a serious breach and may lead to removal from any AWARE role.
- Confidentiality. The identity of a person raising a concern is known only to those handling it. It is shared further only with that person's consent, where needed to protect someone from harm, or where the law requires.
- Records. Each concern, assessment and outcome is recorded and kept securely for seven years. Only those handling a concern can see its records; the founder and any implicated person cannot.
The heading of section 8 was a drafting label and has been renamed. No other policy text has changed.
This procedure supplements Policy 04 (Whistleblower and Complaints) of the July 2026 Core Governance Policies.
1. Why this procedure exists
Policy 04 sends every report to the Chair. At AWARE the founder is the interim chair, and many concerns about AWARE's independence would be concerns about decisions the founder made. A route that ends with the person being complained about is not independent. This procedure fixes that. It also gives the public, athletes, sport organizations and funders one place to raise concerns about AWARE's published commitments.
2. What can be raised
- A funding partner given influence it should not have, such as over curriculum, research, educators, campaigns, or which athletes or teams are served.
- A finding softened, delayed or withheld.
- An athlete or educator used in a partner's marketing, or a partner implying an endorsement.
- Funder names or branding in a session or material for athletes under 18.
- Misuse of the AWARE mark against the Mark-Usage Standard.
- An undeclared conflict of interest, or a related-party arrangement.
- Safeguarding concerns. These follow the Safeguarding Policy first, and any risk to a child goes to police or Child Intervention immediately.
- Anything else in Policy 04: fraud, misuse of funds, or a breach of law or policy.
3. How to raise a concern
- Email info@awarecf.com with "Independence concern" (or "Confidential report") in the subject line.
- By mail to the Foundation's registered office, marked "Confidential: Independence concern".
- Anonymously by either route. Anonymous concerns are investigated as far as the information allows.
Reports to info@awarecf.com marked "Independence concern" are routed to the two non-founding directors. The founder does not receive or screen a concern about the founder.
4. Who handles it
| Stage | Before independent directors are seated | After independent directors are seated |
|---|---|---|
| Receipt and logging | The two non-founding directors | Designated independent director (the "Independence Lead") |
| Assessment | The two non-founding directors | Independence Lead plus one other independent director |
| Investigation | The two non-founding directors, with an external reviewer appointed by them where the concern involves the founder or a partner; by default, the Foundation's external legal counsel | Independence Lead, or an external reviewer |
| Decision | Full board, with any implicated person absent | Independent directors |
The founder, any implicated director and any implicated staff member are excluded from every stage.
5. Timelines
- Acknowledgement within 5 business days.
- An assessment, and a decision on whether to investigate, within 15 business days.
- Findings within 60 days, or an explanation of the delay.
- The person raising the concern is told the outcome, subject to the privacy of others.
6. Outcomes and publication
Where a concern is substantiated, the board acts. Depending on the concern, that may mean:
- correcting a publication;
- withdrawing mark permission;
- terminating a funding agreement, as the funding agreement provides;
- removing a person from their role;
- changing a policy.
Every year, AWARE publishes the number of concerns received, by category, and the number substantiated. Substantiated breaches of the independence terms are described publicly, including the partner involved where a partner breached its agreement.
7. Protection
No one is penalized for raising a concern in good faith. Policy 04's non-retaliation, confidentiality and record-keeping rules apply. Nothing here stops anyone from taking a concern to the police, Alberta Corporate Registry, the Office of the Information and Privacy Commissioner, their sport's integrity channel, or any regulator.
8. Summary published on the Accountability page
Raising a concern. If you believe we have broken one of our own commitments, email info@awarecf.com with "Independence concern" in the subject. You might see a partner given influence, a finding softened, an athlete used in marketing, or a funder named in a youth session. The founder does not handle concerns about the founder. Until independent directors are seated, concerns go to the two non-founding directors and, where needed, an external reviewer. After that, an independent director leads. We acknowledge within 5 business days, report findings within 60 days, and publish a count of concerns and outcomes every year. Any risk to a young person goes straight to police or Child Intervention.
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