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Form 990 Policy and Memo

Form 990 Series – Whistleblower Policy and Memorandum

This memorandum includes a sample whistleblower policy, as well as a discussion of the legal rationale and background for the policy and considerations for implementation. This policy and memo, designed for legal counsel advising California nonprofits exempt under section 501(c)(3) of the Internal Revenue Code, are part of the Form 990 Policy Series, which was developed by a group of lawyers practicing nonprofit law in order to assist nonprofits in addressing the Form 990 governance questions.

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