1. Purpose
Operating Co is committed to providing protected channels for reporting suspected misconduct, including fraud, financial impropriety, sanctions violations, harassment, or any violation of law or company policy.
2. Reporting Channels
- Email: [email protected] (monitored by independent ombudsperson).
- Anonymous portal: TBD (planned Q3 2026).
- Direct to Council: any Council member may receive a report and route it.
- Direct to General Counsel: [email protected].
3. Anti-Retaliation
No employee, contractor, vendor, Foundation, Grantee, or third party who in good faith makes a report under this policy will be subject to retaliation. Retaliation is itself a violation of company policy and grounds for termination, contract cancellation, and Bad-Actor Registry inclusion as applicable.
4. Investigation
Reports are investigated promptly and confidentially. The Reporter is informed of the outcome where lawfully permitted. Material findings are reported to the Audit Committee of the Operating Co board (when constituted) and, where warranted, to law enforcement and regulators.
5. Statutory Protections
This policy supplements (does not replace) statutory whistleblower protections under the Sarbanes-Oxley Act, Dodd-Frank, the False Claims Act, the EU Whistleblower Directive, and equivalent jurisdictional laws.