Greater Houston Community Foundation
Reporting of Unethical/Illegal Conduct & Non-Retaliation Policy
Greater Houston Community Foundation 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.
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 Greater Houston Community Foundation Governing Board member, officer, employee, donor, grantee, contractor, or vendor as the action relates to Foundation activities, or if an action needs to be taken in order for the Foundation to be in compliance with law or appropriate ethical standards, a Governing Board member, officer, or employee of Greater Houston Community Foundation may address the issue directly by going to any officer of the Foundation, including the President, as needed until matters are satisfactorily resolved. It is important that the Foundation knows about unlawful or improper behavior including, but not limited to, any of the following conduct: theft; financial reporting that is intentionally misleading; improper or undocumented financial transactions; destroying or tampering with any record or document with the intent to obstruct a pending or contemplated audit, review, or investigation; improper use of Foundation assets; corruption or bribery; insider trading; payment for services or good that are not rendered or delivered; violation of the Foundation’s Conflict of Interest Policy; any other improper occurrence regarding cash, financial procedures, or financial reporting; other illegal activities.
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 Greater Houston Community Foundation’s General Counsel.
To anonymously communicate any concerns, please contact Fulcrum Inquiry, a 3rd party contracted by Greater Houston Community Foundation, who can receive tips or allegations of types of wrongdoing.
Complaints may be brought to Fulcrum’s attention using any of the following methods:
- Calling (213) 596-1912 (8a-6p Pacific time)
- By using the web form at www.fulcrum.com/ghcf.htm
- By sending an email to [email protected]
- By sending US Mail addressed to: Fulcrum Inquiry, Whistleblower Department, 888 S. Figueroa St., Suite 2000, Los Angeles, CA 90017
- By sending a fax to (213) 891-1300
515 Post Oak Blvd., Suite 1000, Houston TX 77027 | 713-333-2200 | www.ghcf.org