Stocken Family Foundation Whistleblower Policy

Article I: Purpose The purpose of this Whistleblower Policy is to encourage employees, volunteers, officers, and directors of the Stocken Family Foundation (the "Foundation") to report any suspected violations of law, corporate policies, or ethical standards without fear of retaliation. The policy is intended to comply with the New York Nonprofit Revitalization Act and to promote ethical conduct and integrity in all Foundation activities.

Article II: Reporting Responsibility It is the responsibility of all employees, volunteers, officers, and directors to report concerns regarding violations or suspected violations of the Foundation’s policies, laws, or ethical standards.

Article III: Reporting Procedure Reports of suspected misconduct or violations should be submitted promptly to the Foundation’s Compliance Officer, who is responsible for investigating all reported complaints. If the Compliance Officer is the subject of the complaint, the report should be made directly to the President of the Board.

Reports can be made confidentially and anonymously. Reports should be factual, contain as much specific information as possible, and be made in good faith.

Article IV: No Retaliation No employee, volunteer, officer, or director who in good faith reports a violation shall suffer harassment, retaliation, or adverse employment consequences. Any individual who retaliates against someone who has reported a violation in good faith is subject to disciplinary action, up to and including termination.

Article V: Compliance Officer The Compliance Officer is responsible for investigating and resolving all complaints and allegations concerning violations. The Compliance Officer has direct access to the President of the Board and is required to report at least annually to the Board on compliance activity.

Article VI: Acting in Good Faith Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly false will be viewed as a serious disciplinary offense.

Article VII: Confidentiality Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Article VIII: Handling of Reported Violations The Compliance Officer will notify the sender and acknowledge receipt of the reported violation within five business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.