Purpose

This Whistleblower Policy is designed to provide a mechanism for employees and others to raise good faith concerns regarding suspected violations of law or Glenhouse Sports policies.

Scope

This policy applies to all Glenhouse Foundation board members, officers, employees, volunteers, and partners. It covers reporting of activities that may be:

• Illegal or fraudulent
• In violation of organizational policies
• Unethical or dishonest
• In violation of regulations or laws

Reportable Activities

Examples of reportable activities include, but are not limited to:

• Financial improprieties or fraud
• Conflicts of interest
• Misuse of foundation assets
• Violations of grant-making policies
• Discrimination or harassment
• Safety or environmental issues

Reporting Procedure

Concerns should be reported through one of these channels:

• Direct communication with a supervisor
• Report to the Board of Directors
• Confidential email to ethics@weareglenhouse.com
• Online reporting through our secure reporting system

Protection from Retaliation

The Glenhouse Foundation strictly prohibits retaliation against anyone who reports concerns in good faith. Protected activities include:

• Making a report under this policy
• Participating in investigations
• Providing information to law enforcement
• Testifying in proceedings

Confidentiality

Reports may be submitted anonymously. All reports will be handled with the utmost confidentiality possible, consistent with the need to conduct an adequate investigation and take appropriate corrective action.

Investigation Process

All reports will be promptly investigated. The investigation process includes:

• Initial assessment of the report
• Assignment of appropriate investigator
• Gathering and analysis of evidence
• Documentation of findings
• Recommendation of corrective actions

Good Faith Reporting

Anyone filing a report must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation. False or malicious allegations may result in disciplinary action.

Contact Information

For questions about this policy or to report concerns:

• Email: ethics@weareglenhouse.com
• Phone: [Confidential Hotline Number]
• Mail: Ethics Committee, The Glenhouse Foundation [Address]