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WHISTLEBLOWER POLICY

Reporting of Unethical/Illegal Conduct and Non-Retaliation Policy

The Greater Houston Community Foundation (“GHCF”) is committed to lawful and ethical behavior in all of its activities and requires its Governing Board members, officers and employees to conduct themselves in a manner that complies with all applicable laws and regulations. This Policy is intended to encourage employees and others to raise serious concerns without fear of retaliation in any form.

The GHCF website shall be utilized for employees and others to anonymously communicate any concerns to the GHCF management. A copy of this policy will also be made a part of the GHCF Employee Manual.

If at any time a concern exists regarding the propriety or legality of any action contemplated to be taken or that has been taken by any GHCF Governing Board member, officer, employee, donor, grantee, contractor, or vendor as the action relates to GHCF activities, or if an action needs to be taken in order for GHCF to be in compliance with law or appropriate ethical standards, a Governing Board member, officer or employee of GHCF may address the issue directly by going to any officer of GHCF, including the President of GHCF, as needed until matters are satisfactorily resolved.

Alternatively, if you are not comfortable speaking to a manager or the President or do not feel your issue has been properly addressed, you may contact the Chair of the GHCF Governing Board, the Chair of the GHCF Audit & Risk Committee, or GHCF’s legal counsel. Contact information for these individuals is shown at the end of this policy.

Under this policy (sometimes referred to as a “whistleblower policy”), those who report illegal or improper activity will be protected. Efforts will be made to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. The individual making the report will not be discharged, threatened, harassed, or discriminated against for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. Likewise, any unsubstantiated allegations that prove to be have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

The Audit & Risk Committee of the Governing Board shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The Chair of the Governing Board and/or the designated legal counsel shall address all other complaints regarding the propriety or legality of an action or proposed action. All complaints shall be addressed within ten days of the receipt of the complaint by either a manager, the President, the Chair of the Governing Board, the Chair of the Audit & Risk Committee, or GHCF’s designated legal counsel.

Bruce R. Bilger
Chair, GHCF Governing Board
bruce.bilger@lazard.com

Julianne Gorte
Chair, Audit & Risk Committee
jkgorte@comcast.net

William H. Caudill
Norton Rose Fulbright
1301 McKinney, Suite 5100
Houston, Texas 77010
713-651-5292