Revised March 8, 2010

This policy applies to any irregularity involving employees or Trustees of the Foundation as well as grantees, consultants, vendors, contractors or any other parties with a business relationship with the Foundation. Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position, title or relationship to the Foundation.

Foundation management and the Board of Trustees are responsible for the detection and prevention of fraud, misappropriation and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Fraud includes, but is not limited to, the following:

• Self-dealing, private inurement and private benefit (i.e., Foundation assets being used for personal gain or benefit).
• Supplying false or misleading information about the Foundation’s financial documents, including the tax return.
• Providing false information to or withholding material information from the Foundation’s auditors.
• Violations of the conflict-of-interest policy.
• Payment for services or goods that are not rendered or delivered.
• Accepting or seeking anything of material value from grantees, contractors, vendors or people providing services or materials to the Foundation. (Excepted are gifts, honoraria, and entertainment as defined in the Board of Trustees Conflict-of-Interest/Duality-of-Interest Policy.) 

Each member of the management team is expected to be familiar with the types of improprieties that might occur within his or her area of responsibility, and must be alert for any indication of irregularity. An employee who discovers or suspects fraudulent activity should immediately contact, as he or she deems appropriate, any member of the Reporting Committee (Committee), which shall consist of the President/Chief Executive Officer, Vice President of Finance/Treasurer, Director of Human Resources, Chair of the Board and Chair of the Audit Committee. The Chair of the Board and/or the CEO will coordinate all investigations with legal counsel, while keeping the full Committee informed. If the reported allegations are made against the Chair of the Board and/or the CEO, the investigation will be handled by any other member of the Committee and outside legal counsel. Any member of the Committee included in the complaint will be excused from deliberations. The employee or other complainant, to the extent practicable, will remain anonymous bymaking a report through any of the above individuals or by contacting reportingcommittee@kresge.org. All correspondence to this address will be forwarded to the Committee for further review or action. Any identification about the sender will be removed unless necessary for the investigation. The Committee, to the extent practicable, will treat all information received confidentially. Further, the Committee will acknowledge receipt of any complaint within five business days, providing notification to the employee or other complainant of the steps involved for the review, investigation and resolution of the complaint.

Members of the Committee will have free and unrestricted access to all Foundation records and premises. The Committee has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, the Committee will issue reports to appropriate personnel and, if appropriate, to the full Board of Trustees through the Audit Committee. Decisions to prosecute or refer the examination results to the appropriate law enforcement or regulatory agencies for independent investigation will be made in conjunction with legal counsel and the President, as will final decisions on disposition of the case. If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by management and/or the Board, and if it is determined appropriate, by outside counsel, before any such action is taken.

Investigation results will not be disclosed to or discussed with anyone other than those who have a need to know. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Committee. No information concerning the status of an investigation will be given out.

The Committee is responsible for the administration, interpretation and application of this policy.  Any revisions to the policy will be submitted to the Board for approval. The policy will be reviewed periodically by the Audit Committee and revised as needed.