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In order to create a safe, secure and ethical workplace, GBH has established a relationship with a hotline/helpline firm, EthicsPoint. EthicsPoint provides Staff and other stakeholders additional methods to raise concerns about possible safety or security issues or unethical or inappropriate behavior within our community. Issues may be filed by phone or through the EthicsPoint website, and, if preferred, may be made anonymously. 

To submit a potential allegation or question using EthicsPoint, please log on to www.ethicspoint.com and click on “File a Report” where you can search for GBH’s specific reporting page.  If you prefer to communicate by phone, please call 888-359-6297.  If you have questions, please contact GBH’s Compliance Department or Human Resources (617) 300-2000 (the “Whistleblower Contacts”). OTHER INCLUDES ERIC BRASS AND ANN DEXTER CONTACT INFO

• Reporting Responsibility
  
  It is the responsibility of all trustees, officers and employees to comply with the Foundation’s Code and to report violations or suspected violations in accordance with this Whistleblower Policy.
  
  • No Retaliation
  
  No trustee, officer or employee who in good faith reports a violation of any of the provisions of either of the Codes 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 the Foundation rather than seeking resolution outside the Foundation.
• Reporting Violations
  
  The Codes address the Foundation’s open door policy and suggest that employees share their questions, concerns, suggestions or complaints with any of the individuals identified in this policy. In most cases, an employee’s supervisor is in the best position to address an area of concern.  However, if an employee is not comfortable speaking with his/her supervisor or is not satisfied with the supervisor’s response, the employee should speak to his/her vice-president, to the Whistleblower Contacts, to the Foundation’s General Counsel or to any of the other lawyers in Business and Legal Affairs.  Supervisors and managers are required to immediately report suspected violations of the Codes, in writing, to either of the Foundation’s Compliance Officers, who have specific and exclusive responsibility to investigate all reported violations.  For suspected fraud, or when an employee is not satisfied with or is uncomfortable following the Foundation’s open door policy, individuals should contact the Foundation’s Whistleblower Contacts directly.
  
  • Whistleblower Contacts
  
  The Foundation has named two senior employees as Whistleblower Contacts because of the size of the organization and the possibility that an employee might not be comfortable reporting to one of the named individuals. 
  
  The Foundation’s Whistleblower Contacts are responsible for investigating and resolving all reported complaints and allegations concerning violations of the Codes and, as either deems appropriate, should advise the President and/or the Audit Committee Chair.  A Whistleblower Contact shall not participate in the investigation of any complaint involving that Officer or anyone who reports to that Officer.  The Whistleblower Contacts shall have direct access to the Audit Committee of the Board of Trustees, report to the Audit Committee at least annually and identify in that report any material.  Reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. 
  
  • Acting in Good Faith
  
  Anyone filing a complaint concerning a violation or suspected violation of the Codes must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of one or more provisions of either or both of the Codes. 
  
  Any allegation that is not substantiated and that proves to have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.
  
  • Confidentiality
  
  Violations or suspected violations of the Foundation’s codes 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 consistent with the Foundation’s overriding need to conduct an adequate investigation. Complainants should recognize the limits that are inherent in anonymous or confidential complaints. It may be difficult to take corrective action based on these types of complaints. However, all complaints will be investigated.
  
  • Handling of Reported Violations
  
  A Whistleblower Contact receiving a complaint will acknowledge receipt of a reported violation or suspected violation promptly, generally within five business days.  All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.

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Federal regulations require Investigators to disclose certain financial interests (defined below) to ensure that the design, conduct or reporting of federally-funded projects will not be biased.  This procedure describes the conditions under which these financial interests should be disclosed by Investigators, regardless of whether the Investigator is an employee of GBH or not.  The procedure is applicable to all research and educational activities supported by the National Science Foundation (NSF) and to all research activities supported by the Public Health Service (PHS) and other federal agencies, and by other funders and programs that specifically request review consistent with federal regulations on objectivity in research. 

1. Definitions

Investigator:  For purposes of this procedure, Investigator means any individual, subawardee, contractor or collaborator who shares responsibility for the design, conduct or reporting of the results of a sponsored project, and includes the Principal Investigator.

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• Salary, royalties or other remuneration from GBH or from the subrecipient organization when an Investigator is employed by the subrecipient;
• Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
• Income from service on advisory committees or review panels for public or nonprofit entities; and
• Salaries, royalties or other payments that, when aggregated with those of a spouse and dependent children, are not reasonably expected to exceed $5,000 during the past twelve months or over any twelve month period during the term of the project.

1. Policy

Disclosure Requirement

Investigators are required to disclose any Significant Financial Interest (as defined above) in any federally-funded project which would reasonably appear to be affected by the work that will be performed on the Project and/or any Significant Financial Interests in entities whose financial interests (e.g., its earnings, value, sales of its products) would reasonably appear to be affected by the project.

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