The ClimateWorks Foundation was established to reduce global greenhouse gas emissions exclusively for the public good. The board and our supporting donor institutions honor these values by requiring the highest ethical standards of the directors, officers, and staff; by using donor contributions efficiently for ClimateWorks’ philanthropic objectives; and by taking measures to assure that decisions are not influenced by self-interest. This policy is intended to provide guidance on how to deal appropriately with situations that involve possible illegal, fraudulent, or dishonest use or misuse of the foundation’s resources or property.
ClimateWorks will promptly and discretely investigate any possible fraudulent or dishonest use or misuse of foundation resources or property and will take the appropriate actions set forth in this policy. It is important that the foundation be informed about unlawful or improper behavior such as, but not limited to, any of the following:
This policy does not apply to harassment and safe workplace issues. ClimateWorks’ employee handbook includes policies and complaint procedures relating to such issues.
This policy is intended to encourage and enable directors, employees, volunteers, and other stakeholders to raise concerns within the Foundation for investigation. No director, employee, volunteer, or stakeholder who reports a concern in good faith shall be subject to retaliation, intimidation, or disciplinary action. Any volunteer or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.
Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice or a violation of the policies and procedures of the foundation. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment.
When possible, employees should report concerns to their manager or the next level of management. However, if for any reason employees are not comfortable speaking to a manager, they should contact the President and CEO, the audit committee representative, or our general counsel. Contact information is on the last page of this policy.
All reports will be treated confidentially—consistent with the need to investigate, prevent, or correct the violation. Reports may be written or made orally, and may remain anonymous. Anonymous whistleblowers must provide sufficient corroborating evidence to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations will not be undertaken without verifiable evidentiary support. Because investigators are unable to interview anonymous whistleblowers, it may be more difficult to evaluate the credibility of the allegations and therefore, less likely to cause an investigation to be initiated.
Managers are required to report suspected fraud or dishonest conduct to the President and CEO. Once the President and CEO is notified, he or she will determine if the allegations are true, if the issue is material, and what actions, if any, are necessary to correct the problem. He or she will inform the Board chair of the complaint.
After concluding the investigation, the President and CEO will issue a full written report to the audit committee, which may conduct another investigation or decide not to investigate further. If the audit committee representative is approached directly, the committee will determine if the allegations are true, if the issue is material, and what actions, if any, are necessary to correct the problem. The audit committee will make a written report of its findings and recommendations to the Board of Directors.
The audit committee shall have full authority to investigate concerns raised under this policy and may retain outside legal counsel, accountants, private investigators, or other resources necessary to conduct a full and complete investigation of the allegations.
If the complaint is sent to the general counsel, he or she will determine the proper escalation path.
Directors or other volunteers may submit concerns to the President and CEO or to the audit committee representative. The complaint process will proceed the same way as outlined above from that point forward. If the report is made directly to the general counsel, he or she will determine the proper escalation path.
(as of August 14, 2014)
President and CEO
235 Montgomery Street, #1300
San Francisco, CA 94104
Audit Committee Representative
Sue Tierney (also Board Chair)
Analysis Group, Inc., 111 Huntington Avenue, Tenth Floor
Boston, MA 02199
Caplin & Drysdale, Chartered
One Thomas Circle, N.W. Ste. 1100
Washington, D.C. 20005-5894