WHISTLEBLOWER POLICY
Policy for Reporting Concerns, Complaints, or Violations
And Protection for Whistleblowers
The William and Flora Hewlett Foundation expects its directors, officers, and employees to act
honestly and with integrity, in accordance with high ethical standards, and to comply withapplicable laws, regulations, and Foundation policies in the conduct of their duties. The
Foundation is committed to facilitating open and honest communications in all matterspertaining to its governance, finances, and compliance with applicable laws, regulations, andpolicies, and encourages the reporting of good faith concerns, complaints, and violations.
Any director, officer, or employee who violates or suspects any violation of the law, regulations,Foundation policies, or accounting, auditing, and financial reporting controls must report suchactivity as soon as possible by submitting a report under this policy. It is important that theFoundation be apprised about unlawful or improper behavior including, but not limited to, anyof the following conduct:• theft;• financial reporting that is intentionally misleading;• improper or undocumented financial transactions;• destroying or tampering with any record or document with the intent to obstruct apending or contemplated audit, review or investigation;• improper use of Foundation assets;• corruption or bribery;• insider trading;• payment for services or goods that are not rendered or delivered;• violations of the Foundation’s Conflict of Interest Policy;• any other improper occurrence regarding cash, financial procedures, or financialreporting; and• other illegal activities.
No Retaliation
No employee will be discharged, threatened, discriminated against, or otherwise disadvantagedin any manner because the employee reported in good faith what the employee perceives to bewrongdoing, violations of law or Foundation policy, unethical conduct, or because the employee
cooperated with an investigation of such a report. The Foundation will impose disciplinary
measures, up to and including termination or removal, on anyone who threatens or retaliates

Policy Contact: For questions about this policy, contact the Foundation’s General Counsel.
Last Updated: October 2024

against an employee who makes a good faith report or who assists in the investigation of areport.
Reporting Concerns
Any person with a good faith concern or complaint has a number of options for reporting.
Reports can be made verbally or in writing, and in person or anonymously. To the extent
possible, reports should include documentation supporting the concern. Reports should be as
detailed as possible in order to facilitate investigation.
The Foundation recognizes that there are occasions when someone with knowledge of possible
wrongdoing may not feel comfortable going directly to management and would prefer to raise
concerns in a confidential manner. This Whistleblower Policy and the reporting options set
forth below are designed to facilitate such confidential reporting.
1.

General Counsel. The Foundation’s General Counsel is responsible for theadministration of this Whistleblower Policy. Concerns may be reported to the GeneralCounsel at the following address:
Hewlett Foundation
Attn: Kristy Tsadick, General Counsel
2121 Sand Hill Road
Menlo Park, CA 94025
ktsadick@hewlett.org

2. President or Audit Committee Chair. Concerns may be reported to the Foundation’sPresident or to the Chair of the Audit Committee as follows:
Hewlett Foundation
Attn: President
2121 Sand Hill RoadMenlo Park, CA 94025
orHewlett Foundation
Attn: Chair of the Audit Committee
2121 Sand Hill Road
Menlo Park CA 94025
3. Online Reporting. Concerns may be reported to EthicsPoint, a confidential third-party
reporting service authorized by the Foundation to receive such reports, via telephone
hotline: 1-866-839-5063 or website: http://hewlettfoundation.ethicspoint.com.
EthicsPoint can accept anonymous reports.

4. Outside Law Firm. If for any reason a person feels the other reporting options areinsufficient, they should report concerns to:
Ms. Celia Roady
Morgan Lewis
1111 Pennsylvania Avenue, NW
Washington, DC 20004
celia.roady@morganlewis.com
Ms. Roady is an attorney who has been specifically retained by the Foundation as anindependent agent to collect such reports and ensure that they are reviewed, and that
corrective action is taken when appropriate.
Investigation and Disciplinary Action
The General Counsel will investigate reports involving a Foundation employee (other than anofficer), in the manner they deem appropriate. Any reports involving a Foundation director orofficer, including the President and the General Counsel, will be referred to the Audit
Committee Chair, who will investigate as they deem appropriate. Reports involving the Audit
Committee Chair will be referred to the Chair of the Board.
The Audit Committee will make a recommendation to the Board on how to handle reports,
including any disciplinary action to be taken, involving an officer or director of theFoundation. The Chair of the Board will make a recommendation to the Board on how tohandle reports involving the Chair of the Audit Committee, including any disciplinary action tobe taken. In all cases involving officers or directors, the full board will have the authority tomake the final determination on any disciplinary action. The President or their designee
will have authority over the treatment of all other reports, including any disciplinary action. For
Foundation employees who report their own misconduct, disciplinary action may be mitigated
if the employee is the first to report the misconduct and fully cooperates in the investigation.
The General Counsel will provide an annual summary report of all concerns reported under thispolicy, the results of any investigations, and the action taken to the Audit Committee.
Confidentiality
The Foundation will protect the identity of any person making a report to the extent practicable
given the need to conduct a thorough investigation and take necessary corrective action. The
Foundation cannot promise complete confidentiality, but will act as discreetly as reasonably
possible.