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Non-Retaliation Policy / Whistleblower Policy

Through the Foundation’s core value of “Stewardship,” we acknowledge that the resources of the Foundation are a public trust and are to be used responsibly and for their intended purpose. As such, the Foundation’s Board of Directors, officers, and employees (“Foundation Persons”) must comply with, and frequently go beyond, the laws and regulations applicable to private foundations and must faithfully implement the Foundation’s own policies and procedures. Foundation Persons have the responsibility to report any circumstance of which they have actual knowledge, or a reasonable good faith belief, that the Foundation’s accounting systems, auditing functions, system of internal controls or operating policies are compromised or threatened.

It is the Foundation’s policy to comply with all applicable laws that protect employees against unlawful discrimination or retaliation by their employer as a result of their lawfully reporting information regarding, or the participating in, investigations involving corporate fraud or other violations by the Foundation of federal or state law. Additionally, it is the Foundation’s policy to protect its vendors, contractors, and grantees from retaliation as a result of good faith reporting of a possible violation of federal or state law or concerns about the Foundation’s internal controls or operating policies.  Specifically, the Foundation policy prevents any Foundation Person, vendor, contractor, or grantee from being subject to disciplinary action or retaliation by the Foundation or any or its employees or agents as a result of:

  • disclosing information internally or to a government or law enforcement agency, where there is reasonable cause to believe that the information discloses a violation or possible violation of federal or state law or regulation; or
  • reporting suspected conflicts of interest, self-dealing, unethical behavior or concerns about the Foundation’s accounting systems, auditing functions, system of internal controls or operating policies; or
  • reporting harassment as described in the Foundation’s Employee Handbook.

The Foundation has designated a Compliance Officer who is responsible for administering this policy. The Foundation’s Compliance Officer is our outside legal counsel, Bill Choi, who may be reached at 213-892-7700, bill [at], or by mail c/o Rodriguez, Horii, Choi & Cafferata, 777 South Figueroa Street, Suite 2150, Los Angeles, CA 90017. The Compliance Officer is responsible for receiving, collecting, reviewing, processing and resolving concerns and reports by employees and others on the matters described above and other similar matters.

Procedure for Reporting Suspected Violations

Employees are encouraged to discuss issues and concerns of the type covered by this Policy with their supervisor or any member of senior management who is in turn responsible for informing the Compliance Officer of any concerns raised. If the employee prefers not to discuss these sensitive matters with his or her own supervisor or senior management, the employee may instead present such matters directly to the Compliance Officer. Reports may be submitted verbally or in writing, but the reports should contain enough information to substantiate the concern and allow appropriate investigation to begin.

Reports may be submitted anonymously or not, but the preference is that there be direct and open communication between the reporting employee and the Compliance Officer, with the latter maintaining the employee’s identity in confidence if the situation so warrants non-disclosure in his considered judgment. The Foundation will protect the identity of the person reporting a concern to the greatest extent practicable given the needs to conduct an effective, thorough investigation, to gather facts, comply with legal requirements, and to take any necessary corrective action.  Accordingly, the Foundation cannot promise complete confidentiality, but it will act as discreetly as reasonably possible.

The Compliance Officer will inform the Chair of the Board and the Chair of the Audit Committee of the Board immediately of any alleged fraud or financial malfeasance and shall keep them apprised of the investigation and results.

The Foundation will not tolerate retaliation, intimidation, harassment, discharge, or discrimination, whether direct or indirect, against any Foundation Person, vendor, contractor, grantee, or other person who makes a good faith report or who cooperates with an investigation or complaint. Notwithstanding the prior sentence, the Foundation reserves the right to take appropriate disciplinary action, including termination or removal from office, when the Foundation concludes that such action is warranted. In other words, the Foundation may still take action against a person who has committed an offense even though they cooperate with the investigation.

If any person or organization believes they have been subjected to any action that violates this Policy, they may file a complaint with their own supervisor (if an employee), the Foundation’s CEO, or the Compliance Officer. If it is determined that there has been any improper action in violation of this Policy, such person or organization will be entitled to appropriate corrective action.

The Foundation reserves the right to amend and/or supplement this Whistleblower Policy at any time.  If you have questions about a specific grant’s status or denial, please contact our Grants Management staff at: grants [at]

Updated June 28, 2019.

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