Whistle Blowing Policy


Policy Statement

One of the most valuable assets of Make-A-Wish Foundation International (“we,” “our,” “us,” or “Make-A-Wish International”) is our integrity. Protecting this asset is the job of every director, officer, employee, and volunteer in the Make-A-Wish International community (each individual a “Make-A-Wish Individual” and collectively “Make-A-Wish Individuals”) and its network of affiliates (the “Affiliates”). As representatives of Make-A-Wish International, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
This policy (this “Policy”):
(a) encourages and enables Make-A-Wish Individuals to raise concerns regarding suspected illegal or unethical conduct or practices or violations of the Make-A-Wish International policies on a confidential and, if desired, anonymous basis;
(b) protects Make-A-Wish Individuals from retaliation for raising such concerns; and
(c) establishes policies and procedures for Make-A-Wish International to receive and investigate reported concerns and address and correct inappropriate conduct and actions.


Reporting Responsibility

Every Make-A-Wish Individual has the responsibility to report in good faith any concerns about actual or suspected violations of Make-A-Wish International policies or any applicable law or regulation governing Make-A-Wish International’s operations (each, a “Concern”).
Appropriate subjects to report under this Policy include but are not limited to financial improprieties, accounting or audit matters, ethical violations, or other similar illegal or improper practices, such as:
(a) fraud;
(b) theft;
(c) embezzlement;
(d) bribery or kickbacks;
(e) misuse of Make-A-Wish International assets; and
(f) undisclosed conflicts of interest.

Reporting in Good Faith

Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed could indicate a violation of law, an applicable regulation and/or our ethical standards. Any unfounded allegation that proves to have been made maliciously, recklessly, or knowingly to be false will be viewed as a serious offense and result in disciplinary action, up to and including termination of employment or volunteer status.

Reporting Procedures

All Concerns should be reported as soon as practicable, consistent with this Policy. Make-A-Wish Individuals should first discuss any Concern with their direct supervisors. If a Make-A-Wish Individual is not comfortable discussing an issue with his or her supervisor or believes that it would be inappropriate to do so, the Make-A-Wish Individual should contact the CEO of Make-A-Wish International or the CEO of the applicable Affiliate. If the Make-A-Wish Individual believes disclosure to the CEO of Make-A-Wish International or the applicable Affiliate would likewise be inappropriate, then the disclosure should be made to the Chair of the Make-A-Wish International Board of Directors (the “Board”). The appropriate supervisor, CEO, or Board Chair for purposes of this Policy is referred to as a “Concern Officer.”


    Each supervisor shall report any suspected violation, Concern or complaint reported to such person by Make-A-Wish Individuals to the appropriate Concern Officer, as set forth under the Reporting Procedures Section of this Policy, to assure proper treatment and retention of complaints, Concerns or notices of potential violations. In addition, Make-A-Wish Individuals should take note that persons outside Make-A-Wish International may report complaints or concerns about suspected illegal or unethical conduct or practices or violations of Make-A-Wish International’s policies. These concerns and complaints should be reported immediately on receipt to the applicable Concern Officer.
    Upon receipt of a complaint, Concern or notice of potential violation, the Concern Officer shall notify the reporting individual and acknowledge receipt of each reported Concern, unless the report was submitted anonymously or no return address is provided.
    The Concern Officer shall conduct a prompt, discreet, and objective review or investigation based on the submitted report. Where applicable, the Concern Officer will liaise with the Concern Officer of the relevant Affiliate or International Office. A full investigation may not be possible if a report made anonymously is vague or general. If deemed necessary in his or her sole discretion or upon the recommendation of the Board, the Concern Officer may engage legal counsel, accountants, or other experts to assist in the investigation.
    The Concern Officer may delegate the investigation responsibilities to any Board committee or other individual, including third parties, as long as:
    (a) the delegate is not a subject of the reported Concern; and
    (b) the delegation does not compromise the identity of the Make-A-Wish Individual who reported anonymously or confidentially.
    After his or her investigation, the Concern Officer shall recommend appropriate corrective action to the Board, if warranted by the investigation, oversee the implementation of a resolution based on the determination of the Board, and follow up with the reporting individual, if possible, for closure of the reported Concern.
    All notices or reports of suspected violations, complaints or Concerns received pursuant to this Policy shall be recorded in a written (or electronic) log, indicating the description of the matter reported, the date of the report and the disposition thereof. This log shall be maintained by Make-A-Wish International and a record of the report shall be retained in the log for five years.


    No Make-A-Wish Individual who in good faith reports a Concern or participates in a review or investigation of a Concern shall be subject to harassment, retaliation, or, in the case of an employee or volunteer, adverse consequences to such person’s employment or volunteer status because of such report or participation. This protection extends to Make-A-Wish Individuals who report in good faith, even if the allegations are, after an investigation, not substantiated. Moreover, Make-A-Wish International will not permit any form of intimidation or retaliation against any Make-A-Wish Individual because of any lawful act done to:
    (a) provide information or assist in an investigation regarding any conduct which the Make-A-Wish Individual reasonably believes constitutes a violation of any Make-A-Wish International policies; or
    (b) file, testify, participate in, or otherwise assist in a proceeding relating to a violation of any law, rule, or regulation.
    Any Make-A-Wish Individual who retaliates against someone who in good faith has reported or participated in a review or investigation of a Concern will be subject to discipline, up to and including termination of employment or volunteer status.
    Anyone who believes that a Make-A-Wish Individual has been subject to harassment, retaliation, or adverse employment consequences as a result of making a good faith report or participating in a review or investigation of a Concern should contact the Concern Officer listed under the Reporting Procedures Section of this Policy.


    Make-A-Wish International encourages anyone reporting a Concern to identify themselves in order to facilitate the investigation of the Concern. However, Concerns may be submitted on a confidential and/or anonymous basis. Make-A-Wish International shall take reasonable steps to protect the identity of the Make-A-Wish Individual, and shall keep reports of Concerns confidential to the extent possible, consistent with the need to conduct an adequate investigation. Make-A-Wish International may find it necessary to share information with others, but may only do so on a “need to know” basis.
    Reports may be made anonymously using a fraud signaling mechanism available to all at Convercent, Ethics & Compliance (landing page).


    To ensure that Make-A-Wish International operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its reputation or tax-exempt status, the Audit, Finance, Risk and Investment Committee (the “AFRI Committee”) shall conduct periodic reviews of this Policy. The AFRI Committee shall present any recommended changes, modifications, or deletions of the provisions of this Policy to the Board at its regularly scheduled meeting following the AFRI Committee’s review.


    In the event that the jurisdiction of any Affiliate has more stringent requirements than the requirements pursuant to this Policy, the laws of that jurisdiction shall apply. As per Affiliate policies, every Affiliate must comply with the laws required by its jurisdiction.
    This Policy shall be made posted to all Make-A-Wish Individuals on the website of Make-A-Wish International. Each Affiliate should ensure that they have a policy similar to this Policy in accordance with their local laws.
    Behavior that is inconsistent with the values and commitments in our Code of Ethics and Good Conduct should be immediately corrected. If this is not the case, this may be reported under this Policy or pursuant to the procedure in our Code of Ethics and Good Conduct.
    This Policy was adopted by the Board at its meeting on 13 December 2021.


    Any questions regarding the contents or application of this Policy should be directed to the CEO of Make-A-Wish International.