Artstor Whistleblower Policy

Why Do We Have This Policy?

Artstor is committed to lawful and ethical behavior in all of its activities, and requires that its trustees, officers, employees, consultants, and volunteers conduct themselves in a manner that complies with all applicable laws and policies. We have established this policy in order to encourage individuals who have questions or reservations about the legality or propriety of a particular course of action by Artstor or by individuals associated with Artstor to promptly raise these issues with the appropriate person(s).

Who Is Covered By This Policy?

This policy applies to all of Artstor's trustees, officers, employees, consultants and volunteers, and is available on the Artstor website and also distributed to all trustees, employees and volunteers who provide substantial services to the organization.

Reporting Concerns

If you have a good faith concern regarding the legality or propriety of any action or proposed action to be taken by Artstor or on Artstor's behalf by any trustee, officer, employee or other person, or if you have a good faith belief that action needs to be taken in order for Artstor to be in compliance with applicable laws, policies or ethical standards, you should promptly advise Artstor's Senior Director of Human Resources, or the equivalent person in the event of a reorganization or change in title. This individual is responsible for administering this policy and reporting with respect to it to the Audit Committee of the Board of Trustees. If, for whatever reason, it is not appropriate to raise your concern with this individual, or if you fail to receive a reasonably satisfactory response, you are encouraged to report your concerns to the Artstor General Counsel, President, Chairman of the Board of Trustees, the Audit Committee of the Board of Trustees, or another member of the Board of Trustees.

Reports can be made verbally or in writing, in person or anonymously.

Investigation and Corrective Measures

Artstor will investigate reports under this policy with care and report them to the Audit Committee of the Board of Trustees. Artstor's interest in being thorough in its investigation means that it cannot promise complete confidentiality, but it will act as discretely as reasonably possible. If Artstor discovers a problem, it will promptly take corrective action as it deems necessary.

Retaliation Is Prohibited

Artstor prohibits any attempt to discharge, threaten or discriminate in any manner against any person for reporting in good faith a perceived wrongdoing, violation of law or policy, or other unethical or illegal conduct. Artstor will impose disciplinary measures, up to and including termination, against anyone who threatens or retaliates against a person who makes such a good faith report.

Illustrative Types of Concerns

The following is a non-exhaustive list of the kinds of problems that should be reported:

  • False or misleading information in Artstor's financial or other public documents, including its tax returns,
  • Supplying false or misleading information to, or withholding material information from, Artstor's auditors or Trustees,
  • Embezzlement, or payment for services or goods that are not rendered or delivered,
  • Failure to abide by Artstor's Policy on Conflicts of Interest or otherwise realizing an improper personal gain or benefit from a relationship with Artstor,
  • Violation of Artstor's Equal Employment Opportunity and Anti-Harassment Policy, or
  • Facilitating or concealing any of the above or similar actions.

Other

Any violations of this policy (even unintentional ones) should be immediately disclosed to Artstor's General Counsel or President.

Artstor may amend or supplement this policy at any time.

Last updated June 14, 2013.