Effective Date: 2/20/2025

The KMT2C Foundation ("the Foundation") is committed to conducting its activities with honesty, integrity, accountability, and compliance with all applicable laws and regulations. This Whistleblower Policy encourages directors, officers, employees, volunteers, contractors, committee members, and other individuals acting on behalf of the Foundation to report in good faith any suspected misconduct without fear of retaliation.

The purpose of this policy is to:

• Promote ethical conduct and transparency; 
• Encourage prompt reporting of suspected wrongdoing; 
• Protect individuals who report concerns in good faith; 
• Ensure reports are investigated appropriately and confidentially whenever possible. 

This policy applies to:

• Members of the Board of Directors 
• Officers 
• Employees 
• Volunteers 
• Committee members 
• Independent contractors and consultants 
• Any individual acting on behalf of the Foundation 

Individuals should report any good-faith concern involving actual or suspected misconduct, including but not limited to:

• Fraud or financial impropriety 
• Theft or misuse of Foundation assets 
• Embezzlement 
• Accounting irregularities 
• Falsification of financial records 
• Conflicts of interest not properly disclosed 
• Violations of Foundation policies 
• Violations of applicable federal, state, or local laws 
• Harassment, discrimination, or unethical conduct 
• Abuse of authority 
• Retaliation against someone who has made a protected report 

A report does not need proof of wrongdoing. A reasonable belief based on available information is sufficient.

Whenever practical, concerns should first be reported to the Executive Director or President.

If the concern involves the Executive Director, President, Treasurer, or another senior leader, or if the reporter is uncomfortable making a report to management, the concern should be reported directly to:

Chair of the Board of Directors

If the Board Chair is the subject of the concern, the report should be submitted to any other independent member of the Board of Directors.

Reports may be made verbally or in writing.

Reports should include as much relevant information as possible, including:

• Description of the concern 
• Dates and locations 
• Individuals involved 
• Witnesses, if known 
• Supporting documentation, if available 
• 
  

Anonymous reports will be accepted to the extent permitted by law. However, anonymity may limit the Foundation's ability to investigate thoroughly.

All reports will be reviewed promptly and fairly.

The Foundation will:

• Conduct an appropriate investigation; 
• Preserve confidentiality to the greatest extent possible; 
• Document findings; 
• Take corrective action when warranted. 

Individuals who are the subject of an investigation will be treated fairly throughout the process.

Reports and investigations will be handled as confidentially as reasonably possible while allowing the Foundation to conduct an adequate investigation and comply with legal obligations.

Information will be shared only with individuals who have a legitimate need to know.

The Foundation strictly prohibits retaliation against anyone who:

• Reports a concern in good faith; 
• Participates in an investigation; 
• Assists in resolving a reported concern. 

Retaliation includes, but is not limited to:

• Termination 
• Demotion 
• Harassment 
• Intimidation 
• Threats 
• Discrimination 
• Reduction in responsibilities 
• Any adverse action because an individual made or assisted with a protected report 

Anyone who engages in retaliation may be subject to disciplinary action, including removal from volunteer or Board service, termination of employment, or termination of contractual relationships.

Individuals making reports are expected to act honestly and in good faith.

Knowingly making false allegations, intentionally misleading investigators, or reporting concerns with malicious intent may result in disciplinary action.

A report made in good faith will remain protected even if an investigation determines no wrongdoing occurred.

Any Board member, officer, or employee with a personal or financial interest in the matter under investigation shall recuse themselves from the investigation and any related decision-making.

The Foundation will maintain records of reports, investigations, findings, and resulting actions in accordance with its Record Retention Policy and applicable law.

The Board of Directors has ultimate responsibility for oversight of this policy.

The Board may delegate administration of investigations as appropriate, provided no individual with an actual or perceived conflict of interest participates in the investigation.

The Board of Directors shall periodically review this policy to ensure continued compliance with applicable laws, IRS governance recommendations, and nonprofit best practices.