General
The White House Fellows Foundation and Association (WHFFA) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the WHFFA, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility
It is the responsibility of all directors, officers and employees to report ethics violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation
No director, officer or employee who in good faith reports an ethics violation shall suffer harassment, retaliation or 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 WHFFA prior to seeking resolution outside WHFFA.

Reporting Violations
WHFFA has an open door policy and suggests that employees, directors, and other representatives share their questions, concerns, suggestions or complaints with someone who can address them properly. Suspected ethics violations should be reported to the WHFFA Board President, who has specific and exclusive responsibility to investigate all reported violations.

Compliance Officer
The WHFFA Board President is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his/her discretion, shall advise the Executive Director and/or the Audit Committee. The WHFFA’s Compliance Officer is the President of the Board of Directors.  The Compliance Officer, Executive Director, or Audit Committee may, in their discretion, engage and involve legal or other professionals to assist in the investigation and resolution of such complaints and allegations.

Accounting and Auditing Matters
The Audit Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The WHFFA Board President shall notify the audit committee of any such complaint and work with the committee until the matter is resolved.

Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

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 WHFFA Board President 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.

Promulgation of Policy
This policy shall be distributed to directors, officers, and employees of the WHFFA, and to the Director of the President’s Commission on White House Fellowships.

Policy Approved by the WHFFA Board of Directors on January 29, 2011.