Whistleblower Policy
THE FOUNDATION IS COMMITTED TO THE ETHICAL BEHAVIOR OF ALL WHO WORK WITH AND FOR THE FOUNDATION, AND HAS RETAINED A THIRD PARTY ADMINISTRATOR TO HANDLE ANY COMPLAINTS OF UNETHICAL OR FRAUDULENT BEHAVIOR. THIS ALLOWS ANYONE TO ANONYMOUSLY REPORT ANY INSTANCES OF SUCH BEHAVIOR.
General
The Skillman Foundation is committed to lawful and ethical behavior in all of its activities and requires trustees, officers, committee members, employees. grantees and consultants to act in accordance with all applicable laws, regulations and policies and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.
The objective of The Skillman Foundation’s Whistleblower Policy (the “Policy”) is to establish policies and procedures to:
- Encourage The Skillman Foundation’s trustees, officers, committee members, employees, grantees and consultants to report what he or she in good faith believes to be a violation of law or policy, fraudulent or dishonest use or misuse of The Skillman Foundation’s resources or property or questionable accounting or auditing matters by The Skillman Foundation or its agents (“whistleblowers”); and
- Ensure the receipt, documentation, retention of records, and resolution of reports received under this Policy
Reporting Violations
The Foundation has engaged Fulcrum Inquiry LLP (“Fulcrum”) to handle whistleblower reports. Legitimate whistleblower complaints received by Fulcrum will be forwarded to the Board of Trustees. Fulcrum will collect complaints using the following means:
- A phone line at 213-596-1903 answered by professional personnel from 8:00 a.m. to 6:00 p.m. Pacific time. Outside these hours, the phone will be answered by an automated voice mail system.
- A web-based form located at www.fulcrum.com/skillman.htm
- E-mail sent to whistle@fulcrum.com
- U.S. mail addressed to Fulcrum Inquiry, Whistleblower Department, 888 S. Figueroa Street, Suite 2000, Los Angeles, CA 90017.
- Fax sent to Fulcrum Inquiry, Whistleblower Department, at 213-891-1300
Reporting obligation
Each trustee, officer, committee member, employee, grantee and consultant of The Skillman Foundation should report what he or she in good faith believes is a violation of law or policy, fraudulent or dishonest use or misuse of The Skillman Foundation’s resources or property or questionable accounting or auditing matters by The Skillman Foundation, its trustees, officers, committee members, employees, grantees, consultants or other agents. The types of concerns that should be reported, include, but are not limited to, the following behaviors:
- providing false or misleading information on The Skillman Foundation’s financial documents, reports, tax returns or other public documents;
- providing false information or withholding material information from The Skillman Foundation’s auditors, accountants, attorneys, trustees or other representatives responsible for ensuring The Skillman Foundation’s compliance with fiscal and legal responsibilities;
- embezzlement, private benefit, or misappropriation of funds;
- violations of The Skillman Foundation’s policies, including but not limited to, its Conflict of Interest Policy, Whistleblower Policy or Documents and Records Policy.
Review Process and Investigation
The status of all pending legitimate whistleblower complaints will be reviewed at each regularly scheduled Board of Trustees meeting. The audit committee of the Board of Trustees will address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. Reports of concerns, complaints, violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation and comply with all legal obligations. Employees of The Skillman Foundation may not retaliate against good faith whistleblowers by adversely affecting the terms or conditions of the whistleblower’s employment or grant status.