Whistleblower Policy

PURPOSE

It is the policy of the Columbia Foundation (the “Foundation”) that its operations are conducted according to the highest standard of integrity, and that its officers, directors, employees, consultants, volunteers, fellows, vendors and other agents avoid situations that might conflict with their responsibilities on behalf of the Foundation. As employees and agents of the Foundation, we must practice honesty and candor.

SCOPE

All officers, directors, employees, including temporary employees, consultants, volunteers, fellows, vendors and other agents are covered by the scope of this policy and its guidelines.

POLICY

It is the responsibility of all those noted in the scope of policy 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 officer, employee and volunteer (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; and
• Protect reporting individuals from retaliatory action.

Reporting individuals must also notify the Foundation if an action needs to be taken in order for the Foundation to be in compliance with law, policy or with generally accepted accounting practices. The types of concerns that should be reported include, but are not limited to, 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, directors 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 community foundation policy including, among others,  confidentiality, conflict of interest, whistleblower, ethics and document retention;
• Discrimination based on race, gender, sexual orientation, ethnicity, disability or other protected classification; and
• Facilitation or concealing any of the above or similar actions.

REPORTING

Employees, Staff and Consultants
Whenever possible, individuals should seek to resolve concerns by reporting issues directly to his/her supervisor or to the next level of management, as needed, until matters are satisfactorily resolved. If, for any reason, an individual is not comfortable speaking to a manager or does not believe the issue is being properly addressed, the individual may contact the president & CEO. If an individual does not believe that these channels of communication can or should be used to express his/her concerns, the individual may contact the chair of the Foundation’s finance committee or the chair of the Board of Trustees. Whenever practical, reports should be in writing. Contact information for the president & CEO or the chair of the board or finance committee may be obtained from the Foundation’s website or by calling the Foundation at (410) 730-7840.

Directors, Vendors, Volunteers and Agents
Directors, vendors, volunteers and agents may submit concerns to the president & CEO or directly to the chair of the finance committee. If the director, vendor, volunteer or agent is not comfortable reporting to either of these individuals, or if he/she does not believe the issue is being properly addressed, the report should be escalated directly to the chair of the Board of Trustees.

HANDLING OF REPORTED VIOLATION

The Foundation will investigate all reports filed in according with this policy with due care and promptness. Matters reported internally will be investigated by the president & CEO of the Foundation 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 chair of the finance committee.

For matters reported directly to the chair of the finance committee or the president & CEO, acknowledgement of receipt of the complaint will be promptly provided to the complainant if the complainant is known. An investigation will be conducted 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 finance committee shall promptly report its findings to the executive committee of the Board of Trustees.

AUTHORITY OF THE FINANCE COMMITTEE

The finance 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 the committee reasonably believes is necessary to conduct a full and complete investigation of the allegations.

NO RETALIATION

No officers, directors, employees, including temporary employees, consultants, volunteers, vendors or agents who in good faith report a violation of the policy shall suffer harassment, retaliation or adverse consequences. An individual who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This policy is intended to encourage and enable employees and other individuals to raise serious concerns within the Foundation prior to seeking resolution outside the organization.

ACTING IN GOOD FAITH

Anyone filing a complaint concerning a violation or suspected violation of the policy must be acting 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.

CONFIDENTIALITY

Violations or suspected violations may be submitted on a confidential basis by the complainant 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.