As of April 1, 2023

This Whistleblower Policy (“Policy”) has been established to foster a safe, secure, and ethical workplace. To enhance the Policy’s effectiveness, GBH has engaged NAVEX to provide its EthicsPoint hotline/helpline service. EthicsPoint allows 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 WGBH’s specific reporting page. If you prefer to communicate by phone, please call 888-359-6297.

Reporting Responsibility

It is the responsibility of all trustees, officers, and employees to comply with GBH’s policies and to report violations or suspected violations in accordance with this Policy.

Reporting Violations

GBH maintains an open-door policy and suggests 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 that supervisor or is not satisfied with the supervisor’s response, the employee should speak with the appropriate vice-president, any Whistleblower Contact, or any Human Resource Business Partner. Supervisors and managers are required to immediately report suspected violations of GBH policies, in writing, to any of the Whistleblower Contacts, who have specific and exclusive responsibility to investigate all reported violations. Again, an employee may report the concern directly to EthicsPoint.

Whistleblower Contacts

GBH has named senior employees as Whistleblower Contacts because of the size of the organization and the possibility that an employee might not be comfortable reporting to any of the individuals mentioned above. These Whistleblower Contacts are Ann Dexter (Vice President of Human Resources), Susan Rosen (Interim General Counsel), and Eric Brass (Chief Compliance Officer and Corporate Counsel). The Whistleblower Contacts are responsible for investigating and resolving all reported complaints and allegations concerning violations of the policies and, as appropriate, should advise the President, COO, and/or the Audit Committee Chair. A Whistleblower Contact shall not participate in the investigation of any complaint involving, or reporting to, that Contact person. The Whistleblower Contacts have direct access to the Audit Committee of the Board of Trustees. They periodically report to the Audit Committee and identify in those reports any material reported concerns or complaints regarding corporate accounting practices, internal controls or auditing, or potential noncompliance with GBH’s various policies.

No Retaliation

No person who in good faith reports a violation of any of the provisions of the policies 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 Policy is intended to encourage and enable employees and others to raise serious concerns within GBH rather than seeking resolution from the outside.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the policies must act in good faith and have reasonable grounds for believing the information disclosed indicates a policy violation.

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.

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.

Confidentiality

Reports of violations or suspected violations of GBH’s policies may be submitted on a confidential basis or anonymously. Reports of violations or suspected violations will be kept confidential to the extent consistent with GBH’s overriding need to conduct an adequate investigation, protect the safety of other individuals, or comply with legal requirements. Complainants should recognize the limits that are inherent in anonymous or confidential complaints. It may be difficult to obtain all pertinent information or take corrective action based on these types of complaints. However, all complaints will be investigated.

Additional Information

Questions about this Policy should be directed to any of the Whistleblower Contacts mentioned above or GBH Human Resources.


  • No labels