Whistleblower Policy

General
The Greater Cincinnati Foundation (“the Foundation”) Code of Ethics and Conduct (“Code”) requires all employees to observe the highest standard of business and personal ethics in the conduct of their duties and responsibilities. As representatives of the Foundation, employees must practice honesty and integrity in fulfilling responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility
It is the responsibility of all employees to comply with the Code and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation
No employee who in good faith reports a violation of the Code shall suffer harassment or retaliation, nor will he or she suffer an adverse employment consequence. 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. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Foundation prior to seeking resolution outside the Foundation.

Reporting Violations
The Code addresses the Foundation’s open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor’s response, the employee is encouraged to speak with anyone in management that he or she is comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code to the Foundation’s Outside Legal Counsel, who acts in a “Compliance Officer” capacity for GCF.   The “Compliance Officer” has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or if an employee is either not satisfied or uncomfortable even after following the Foundation’s open door policy, the employee should contact the Foundation’s “Compliance Officer” directly.

Compliance Officer
The Foundation’s Compliance Officer, currently GCF’s Outside Legal Counsel1, is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his or her discretion, for advising the President/CEO and/or the Governance Committee. The Compliance Officer is required to report, at least annually, to the Governance Committee on compliance activity.

Accounting and Auditing Matters
The Governance Committee shall delegate action relating to concerns and complaints regarding the Foundation’s accounting practices, internal controls and auditing to the Audit Committee. The Compliance Officer shall work with the Audit Committee until the matter is resolved.

Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and have reasonable grounds for believing that the information disclosed indicates a violation of the Code. Any allegations that prove to be false or unsubstantiated, and which prove to have been made maliciously or knowingly, will be viewed as a serious offense requiring disciplinary action.

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.

Handling of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.