POL-001 // GOVERNANCE
Whistleblower and non-retaliation policy.
This policy explains how to raise a concern about Future Vanguard LLC, what we will do with it, and the protections that apply to you. It is written to be read by the person considering whether to speak up, not by a lawyer.
01Purpose
Future Vanguard LLC performs work for government customers. Public money and public trust are involved. That makes it essential that anyone who sees something wrong can say so without fear, and that what they report is actually looked into.
This policy exists to make raising a concern safe, simple, and effective. It applies to the company's own conduct, the conduct of its people, and the conduct of anyone acting on its behalf.
02Who this covers
Anyone may use this channel. It is specifically intended for:
- Employees and officers of Future Vanguard LLC
- Independent contractors and subcontractors, and their personnel
- Government customers, contracting officers, and agency staff
- Suppliers, vendors, and teaming partners
- Members of the public affected by our work
You do not need a relationship with the company to report. You do not need proof. You do not need to be certain.
03What to report
Report anything you reasonably believe is improper. Common examples:
- Billing and timekeeping. Hours charged that were not worked, costs billed to the wrong contract, invoices that overstate what was delivered.
- Fraud, waste, or abuse involving a government contract, grant, or any federal or state funds.
- Misrepresentation of work. Claiming capability, past performance, certifications, or delivered functionality that does not exist. Presenting a prototype as a delivered system. Overstating socioeconomic or registration status.
- Conflicts of interest, undisclosed relationships, kickbacks, or improper gifts.
- Data, privacy, and security. Mishandled personal data, an unreported breach, weak controls being concealed rather than fixed.
- Safety. Anything creating a substantial and specific danger to health or safety.
- Discrimination, harassment, or retaliation, including retaliation for a previous report.
- Any violation of law, regulation, or contract requirement, and any instruction to break one.
If you are not sure whether something belongs here, report it. Sorting that out is our job, not yours.
04How to report
Anonymously, through this website
The reporting form accepts fully anonymous reports. If you leave the contact field blank, no name, email, IP address, or browser information is recorded with your report. That is enforced in how the system is built, not merely promised here: the database that stores reports has no field for a network identifier, and the abuse controls that protect the form store only a salted, one-way hash that cannot be linked back to any report.
Every submission returns a case code. Keep it. It lets you check status, read follow-up questions, and answer them, all without identifying yourself. It is the only key to the case and cannot be reissued, including by us.
By name
You may include contact details if you want direct updates. Doing so does not reduce your protection under this policy.
By phone or mail
Call 765-437-8272, or write to Future Vanguard LLC, 1203 Windy Willows Drive, Jacksonville, FL 32225. Mail may be sent without a return address.
05No retaliation
Retaliation against anyone who reports a concern in good faith is prohibited and is itself a serious violation of this policy.
Prohibited retaliation includes dismissal, demotion, suspension, threats, harassment, reduced hours or scope, termination or non-renewal of a contract, withholding of payment, negative references, exclusion from work, and any other action that would discourage a reasonable person from reporting.
Good faith means you honestly believe what you are reporting. It does not mean you are right. A concern that is investigated and found unsubstantiated is still a protected report, and the person who raised it is still protected.
If you believe you are being retaliated against, report that through this same channel, or go directly to the external channels in section 09.
06Confidentiality, and its limits
We will restrict knowledge of a report to those who genuinely need it to investigate or to meet a legal obligation.
We will not promise absolute confidentiality, because we cannot deliver it. If a court, a law, a contracting officer exercising audit rights, or a government investigator compels disclosure, we must comply. Anonymity is the strongest protection available, and the reporting form is built to support it properly.
Be aware that the substance of a report can sometimes identify its source even when a name is never given. If that concerns you, weigh how much detail to include, or use an external channel.
07An honest word about company size
Future Vanguard LLC is a very small company. Reports submitted here are received by the Managing Member, Raleigh Cortez. There is no separate compliance department, no ethics committee, and no independent internal party to route a report around her.
If your concern is about the Managing Member, or about anyone she is closely connected to, do not rely on this internal channel. Use an external channel in section 09. Telling you otherwise would be a false assurance, and a false assurance in a whistleblower policy is worse than no policy.
Where a report concerns a person who would normally handle it, that person is recused. If recusal leaves no impartial internal reviewer, the company will refer the matter to outside counsel or to the relevant agency, and will say so to the reporter through the case record.
08How a report is handled
- Acknowledged within five business days. For anonymous reports the acknowledgement appears on the case record, reachable with your case code.
- Assessed for scope, urgency, and whether anyone must be recused. Safety and active-harm matters take priority over everything else.
- Investigated proportionately: records reviewed, people interviewed, systems examined. We may post follow-up questions to the case record.
- Concluded with a determination, corrective action where warranted, and a closing note on the case record. We aim to close within sixty days and will say so on the record when a matter needs longer.
- Escalated externally where required. Where a report indicates a credible violation of federal criminal law involving fraud, conflict of interest, bribery, or gratuity, or a significant overpayment on a government contract, the company will disclose it in writing to the relevant agency Office of Inspector General and contracting officer.
What we can tell a reporter about the outcome may be limited by privacy obligations owed to others. We will tell you that a determination was reached even when we cannot detail it.
09External channels, and your right to use them
You are never required to report to us first, and nothing in this policy asks you to wait. If you would rather go straight to the government, do that.
- Government Accountability Office, FraudNet. 1-800-424-5454
- Department of Defense Hotline. 1-800-424-9098
- Department of Veterans Affairs OIG Hotline. 1-800-488-8244
- OSHA, for safety and for retaliation complaints. 1-800-321-6742
- The Office of Inspector General of the contracting agency, or the contracting officer directly.
- A Member of Congress, or a congressional committee.
10Legal protections that apply to you
These protections exist independently of this policy. The company cannot reduce them and does not attempt to.
- 41 U.S.C. 4712. An employee of a contractor, subcontractor, grantee, or personal services contractor may not be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing information the employee reasonably believes evidences gross mismanagement of a federal contract, a gross waste of federal funds, an abuse of authority, a substantial and specific danger to public health or safety, or a violation of law related to a federal contract.
- 10 U.S.C. 4701. The equivalent protection on Department of Defense contracts.
- 31 U.S.C. 3730(h). The False Claims Act protects employees, contractors, and agents from retaliation for lawful acts done in furtherance of a false claims action or to stop a violation.
- FAR 52.203-17. Contractors must inform their employees of these whistleblower rights. This policy is part of how we do that.
11No agreement restricts lawful reporting
No confidentiality agreement, non-disclosure agreement, employment agreement, contractor agreement, settlement, or company policy prohibits or restricts you from lawfully reporting waste, fraud, or abuse to a government entity authorized to receive it. Any term that appears to do so is void as to that reporting, and you do not need our permission to make such a report.
This reflects FAR 52.203-19, which prohibits contractors from requiring internal confidentiality agreements that restrict such reporting.
12Reports made in bad faith
This policy protects good-faith reporting. It does not protect knowingly fabricating an allegation to harm someone. A report that is merely mistaken is protected. A report that is deliberately false is not, and may itself be treated as misconduct.
The company will not use this section as a pretext. The burden of showing bad faith rests with the company, and the default position is that a reporter acted in good faith.
13Records
Reports, case correspondence, and investigation records are retained for at least three years after a case is closed, longer where a contract, audit, or legal hold requires it. Records are kept in a controlled system and are not used for any purpose other than handling the report and meeting legal obligations.
The reporting system stores no network identifier against a report. Deleting an anonymous report's content on request is possible, but note that we cannot verify who is asking beyond possession of the case code.
14Administration
This policy is owned by the Managing Member and is reviewed at least annually, and whenever a contract requirement or a change in law makes review appropriate. Questions about the policy itself, as distinct from a report under it, may be sent to raleigh.cortez@futurevanguard.net.
Future Vanguard LLC, 1203 Windy Willows Drive, Jacksonville, FL 32225. UEI HQ1GXJ6RXJ86. CAGE/NCAGE 230T9.