Northwest Area Foundation

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Whistle Blower

The Northwest Area Foundation is committed to fair, accurate and transparent accounting of financial matters of the Foundation and expects all employees, officers and directors to act in accordance with the highest ethical standards in the performance of their responsibilities for the Foundation. Northwest Area Foundation requires full compliance with all applicable laws, regulations, accounting standards and audit practices applying to private foundations. Northwest Area Foundation relies on all of its employees, officers and directors to conduct themselves in accordance with the requirements and spirit of this policy and to report suspected violations of this policy or other questionable financial, accounting or audit matters without fear of retaliation.

Any employee who has complaints or concerns about Northwest Area Foundation’s accounting, internal accounting controls or auditing matters, or who becomes aware of questionable accounting or auditing matters, is expected to report such matters to the Chair of the Audit Committee of the Foundation if they feel internal management is unable or unwilling to address such concerns. The Chair of the Audit Committee may confer with counsel on how best to proceed.

To raise complaints or concerns about or report a questionable accounting or auditing matter to the Audit Committee Chair, employees should provide details in writing to the Audit Committee Chair at the address listed in the contact list for the board of directors.

In order to facilitate a complete investigation, employees are expected to cooperate and should be prepared to provide as many details as possible, including a description of the questionable practice or behavior, the names of any persons involved, the names of possible witnesses, dates, times, places, and any other available details. Northwest Area Foundation expects all employees with complaints or concerns to come forward with information and prohibits retaliation against employees who, in good faith, raise concerns. Nonetheless, if an employee feels more comfortable doing so, reports may be made confidentially and/or anonymously in the manner described above; however, the Foundation cannot guarantee that reporters’ identities or their reports will remain confidential.

The Audit Committee, under the leadership of its Chair, will oversee the receipt and handling of allegations of questionable accounting or auditing matters, including directing an appropriate investigation and response. Based on its investigation, the Audit Committee, under the leadership of its Chair, will direct Northwest Area Foundation to take prompt and appropriate corrective action in response to the complaint or concern if necessary to ensure compliance with legal and ethical requirements relating to financial, accounting and audit matters. If the Audit Committee determines that a particular complaint or concern is not covered by this policy, it will refer the complaint or concern to the Board Chair or CEO of Northwest Area Foundation for appropriate handling and response.

Reports of questionable accounting or audit practices will be kept confidential to the extent possible consistent with the Audit Committee’s obligation to investigate and correct unlawful or unethical accounting or audit practices. Employees may elect to make complaints anonymously.

Northwest Area Foundation will not retaliate or take any form of reprisal against any person who, in good faith, makes a report pursuant to this policy or who participates in an investigation related to this policy. Any such retaliation or reprisal by a Northwest Area Foundation employee is forbidden. Any employee who retaliates against another employee or a witness as described above will be subject to discipline, up to and including termination. Employees who believe they are subject to retaliation because they have made a report or participated in an investigation should report such suspected retaliation to the Audit Committee Chair in the same manner as described above for the reporting of questionable practices.

Questions about this policy should be directed to the Chair of the Audit Committee.