Commitment to Ethical Behavior
The Foundation is committed to lawful and ethical behavior in all our activities. We expect staff to conduct themselves in compliance with all applicable laws and regulations and with the highest integrity. As an employee of the Foundation, if you are aware of any improprieties or have any concerns, you should report them in accordance with this Policy.
Avenues of Reporting
We have established several different avenues for staff to report any concerns regarding the propriety or legality of any action contemplated to be taken or that has been taken by the Foundation or any other employee, including any financial improprieties. An employee with any such concerns should take one or more of the following actions:
- Promptly advise the Vice President and General Counsel
- Promptly advise the Chair of the Foundation’s Audit Committee (as reflected on the Foundation’s website)
- Promptly advise the Director of People and Culture
Report the matter online to EthicsPoint, a third party service provider, or by phone at 844-773-7421. This report can be made anonymously. EthicsPoint will then communicate with the Foundation so appropriate investigation and action can be taken.
Commitment to a Fair Investigation of Concerns Expressed
The Foundation is committed to investigating promptly any concerns reported. Staff who choose to report anonymously should keep in mind, that if their identities are not known, it may be more difficult to conduct a thorough investigation or provide protection against claims of retaliation. An anonymous allegation will not alone provide a basis for disciplinary action against a person named in the allegation. An investigation of an anonymous allegation will serve as a basis for a disciplinary or other action only if it provides evidence that corroborates an anonymous allegation.
Confidentiality and Limitations
Every effort will be made to investigate a report by a staff member as discretely as possible and to protect confidentiality as best as possible under the circumstances. The identity of the person conveying the concern (if not made anonymously) will be conveyed to other Foundation personnel or counsel retained by the Foundation only on a need-to-know basis to permit an investigation to be undertaken (if appropriate) and to respond to the concerns expressed.
The Foundation cannot, however, promise complete confidentiality in every instance. Circumstances in which the Foundation cannot assure absolute confidentiality includes instances (i) where the staff member expressing the concern consents to disclosure; (ii) the allegations made were knowingly false or made with reckless disregard whether they were true or false; (iii) there is a risk of imminent danger or serious harm to other individuals; and (iv) the Foundation is required to disclose the information by law. The Foundation will inform the person expressing the concern regarding the limitations on confidentiality at the earliest opportunity.
No employee will be discharged, threatened, or discriminated against in any manner for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct or in cooperating with any such investigation.
Updated September 2015