- It is the policy of The Columbus Foundation (hereafter, the “Foundation”) that its operations are conducted according to the highest standard of integrity, and that its Governing Committee members, officers, employees, consultants, volunteers, vendors, and other agents avoid situations that might conflict with their responsibilities on behalf of the Foundation. Such individuals must practice honesty and candor.
- All Governing Committee members, officers, employees, consultants, volunteers, vendors, and other agents, are covered by the scope of this policy and its guidelines. This policy shall also apply to Community Foundations, Inc. and each supporting organization of The Columbus Foundation.
- It is the responsibility of all those noted in the above Scope of Policy (“reporting individuals”) to comply with this whistleblower policy by reporting violations or suspected violations in accordance with this policy.
- The objectives of the Foundation’s whistleblower policy are to establish policies and procedures to:
- Prevent or detect and correct improper activities.
- Encourage each reporting individual to report what he or she in good faith believes to be a material violation of law or policy or questionable accounting or auditing matter by the Foundation.
- Ensure the receipt, documentation, retention of records, and resolution of reports received under this policy.
- Protect reporting individuals from retaliatory action.
- Reporting individuals should notify the Foundation if an action needs to be taken in order for the Foundation to be in compliance with law, policy, or generally accepted accounting practices. The types of concerns that should be reported include, for purposes of illustration and without limitation, the following:
- Providing false or misleading information in the Foundation’s financial documents, grant reports, tax returns, or other public documents
- Providing false information to or withholding material information from the Foundation’s auditors, accountants, lawyers, Governing Committee members, or other representatives responsible for ensuring the Foundation’s compliance with fiscal and legal responsibilities
- Embezzlement, private benefit, or misappropriation of funds
- Material violation of Foundation policies including, among others, confidentiality, conflict of interest and ethics, whistleblower, and document retention
- Discrimination based on race, gender, sexual orientation, ancestry, disability, or other status protected by law or policy
- Facilitation or concealing any of the above or similar actions
- Employees – Whenever possible, employees should seek to resolve concerns by reporting issues directly to his/her manager or to the next level of management, as needed, until matters are satisfactorily resolved. If, for any reason, an employee is not comfortable speaking to a manager or does not believe the issue is being properly addressed, the employee may contact the Director of Human Resources or the President and CEO. If an employee does not believe that these channels of communication can or should be used to express his/her concerns, the employee should contact The Network. The Network is an independent organization operating 24 hours a day, 7 days a week, to receive confidential telephone calls to report unethical or illegal workplace activities. The Network in turn will confidentially report this information to the Chairman of the Foundation’s Governing Committee. The Network’s telephone number is 877-888-0002.
- Other reporting individuals – Reporting individuals other than employees should submit concerns to the President and CEO. If such a reporting individual is not comfortable reporting to the President and CEO or if he/she does not believe the issue is being properly addressed, this individual should contact the Network. The Network is an independent organization operating 24 hours a day, 7 days a week, to receive confidential telephone calls to report unethical or illegal workplace activities. The Network in turn will confidentially report this information to the Chairman of the Foundation’s Governing Committee. The Network’s telephone number is 877-888-0002.
Handling of Reported Violations
- The Foundation will investigate all reports filed in accordance with this policy with due care and promptness. Matters reported internally by employees without initial resolution will be investigated by the Director of Human Resources or the President and CEO, as the case may be, to determine if the allegations are true, whether the issue is material, and what actions, if any, are necessary to correct the problem. The Foundation staff will issue a full report of all matters raised under this policy to the Foundation’s Governing Committee.
- With respect to matters reported to the Chairman of the Foundation’s Governing Committee, the Chairman shall promptly (generally within five business days) acknowledge receipt of the complaint to the reporting individual if the reporting individual is known. An investigation will be held to determine if the allegations are true, whether the issue is material, and what, if any, corrective action is necessary. Upon the conclusion of this investigation, the Chairman of the Governing Committee shall promptly report the findings to the Governing Committee.
- The Chairman of the Governing Committee shall have full authority to investigate concerns raised in accordance with this policy and may retain outside legal counsel, accountants, private investigators, or any other resource that such Chairman reasonably believes is necessary to conduct a full and complete investigation of the allegations.
- No reporting individuals who in good faith report a violation of the policy shall suffer harassment, retaliation, or adverse consequences. An individual who retaliates against a reporting individual who has made such a report in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable reporting individuals to raise serious concerns within the Foundation prior to seeking resolution outside the organization.
- Any reporting individual must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the policy. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
- Violations or suspected violations may be submitted on a confidential basis by the reporting individual or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.