Reporting of Unethical/Illegal Conduct and Non-Retaliation Policy

(What follows is the foundation’s “whistleblower” policy in its entirety. It is addressed to our employees.)

The foundation is committed to lawful and ethical behavior in all of its activities and requires its employees to conduct themselves in a manner that complies with all applicable laws and regulations. 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 foundation employee, or grantee, contractor, 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, you can address the issue directly by going to your manager or to the next level of management as needed until matters are satisfactorily resolved.

Alternatively, if you are not comfortable speaking to a manager or do not feel your issue has been properly addressed, you may contact the Chief Human Resources Officer, General Counsel, or the Chief Executive Officer. If you do not believe that these channels of communication can/should be used to express their concerns, you may utilize the anonymous hotline service the foundation has established with EthicsPoint. If you are not comfortable with these alternatives you may also contact the foundation’s outside legal counsel. (An internal Web site provides employees with contact information for the foundation’s outside legal counsel.)

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.