Our Policies

CORE (the “Corporation”) requires its directors, officers, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The purpose of this policy is to encourage and enable employees and volunteers of the Corporation to report any action or suspected action taken within the Corporation that is illegal, fraudulent or in violation of any adopted policy of the Corporation, to a source within the Corporation before turning to outside parties for resolution. This policy applies to any matter which is related to the Corporation’s business and does not relate to private acts of an individual not connected to the business of the Corporation. This policy is intended to supplement but not replace the Corporation’s unlawful harassment and discrimination policy, “open door policy” and/or any other grievance procedure, and any applicable state and federal laws governing whistleblowing applicable to nonprofit and charitable organizations.

All employees and volunteers of the Corporation are encouraged to report any action or suspected action taken within the Corporation that is illegal, fraudulent or in violation of any state or federal law (each, a “Violation”). Anyone reporting a Violation must act in good faith, without malice to the Corporation or any individual in the Corporation, and have reasonable grounds for believing that the information shared in the report indicates that a Violation has occurred. Any report which the complainant has made maliciously or any report which the complainant has good reason to believe is false will be viewed as a serious disciplinary offense.

No employee or volunteer who in good faith reports a Violation or cooperates in the investigation of a Violation shall suffer harassment, retaliation or adverse employment or volunteer consequences. Any individual within the Corporation who retaliates against another individual who in good faith has reported a Violation or has cooperated in the investigation of a Violation is subject to discipline, including termination of employment or volunteer status.

If an individual believes that someone who has made a report of a Violation or who has cooperated in the investigation of a Violation is suffering from harassment, retaliation or other adverse employment or volunteer consequences, the individual should contact the Whistleblower Committee.

Any individual who reasonably believes he or she has been retaliated against in violation of this policy shall follow the same procedures as for filing a complaint (outlined in Article 4 below).

If an individual reasonably believes that a Violation has occurred, the individual is encouraged to share his or her questions, concerns, suggestions or complaints through the webform below. The webform is completely anonymous, unless you choose to disclose your name and email. If you do not feel comfortable sharing through the anonymous webform, you can also send a letter with details directly to Core Spaces Corporate Offices (attn: Whistleblower Committee – 1643 N Milwaukee Ave, Chicago, IL).

The Corporation encourages anyone reporting a Violation to identify himself or herself when making a report in order to facilitate the investigation of the Violation. However, reports may be submitted anonymously by not disclosing your name or email in the webform below. Reports of Violations or suspected Violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation, to comply with all applicable laws, and to cooperate with law enforcement authorities. Furthermore, the Corporation will explore anonymous allegations to the extent possible, but will weigh the prudence of continuing such investigations against the likelihood of confirming the alleged facts or circumstances from attributable sources.

The Whistleblower Committee is responsible for promptly investigating all reported Violations and for causing appropriate corrective action to be taken if warranted by the investigation. The initial debrief to discuss next steps for escalation of report with occur within five to ten business days. The complainant will be notified about what actions will be taken with thirty business days, but only to the extent that the complainant’s identity is disclosed or a return address is provided, and consistent with any privacy or confidentiality limitations. If no further action or investigation is to follow, an explanation for the decision will be given to the complainant.

In the event one of the Whistleblower Committee members is suspected of having committed a Violation, then suspected Committee member will be removed from any correspondence on the report and the violation will be handled by the remaining Committee Members, under supervision of the President and or Board of Directors.

The audit committee is responsible for addressing all reported concerns or complaints of Violations relating to corporate accounting practices, internal controls or auditing. Therefore, the Whistleblower Committee must immediately notify the audit committee of any such concern or complaint.

In addition, the Whistleblower Committee will advise the President and/or the audit committee of any other reported Violations, the current status of the investigation, and the outcome or corrective action taken at the conclusion of the investigation.

WHAT IS A WHISTLEBLOWING MATTER, WHAT IS NOT?

What is: Criminal Offences, Regulatory Breaches, Health & Safety Breaches

What is not: Airing Grievances, Complaints about Colleagues or Third Parties (though such complaints can be addressed under the Corporation’s anti-harassment policy, amongst other options)

WHERE CAN I FIND THE CHANNEL TO REPORT?

Send an email to whistleblower@corespaces.comwhistleblower@corespaces.com

WHEN IS IT AVAILABLE?

The email address is available 24/7 to file a report

HOW CAN I REPORT?

Submit the subject and details of the incident to the email address below, the more details and evidence you can provide, the better.

WHY SHOULD YOU BOTHER? WHY CAN YOU TRUST IT?

• The email will be safeguarded and only shared with the members of the committee (listed below).
• You are protected, by law, from any retaliation for submitting a report.
• The committee was constructed of members from diverse company functions within the organization to ensure impartiality and due diligence of each report.

WHAT IS THE CASE MANAGEMENT PROCESS…HOW WILL IT BE FOLLOWED UP, ESCALATED AND INVESTIGATED?

Reports go directly to the Whistleblower Committee. The Whistleblower Committee has 5-10 business days to hold an initial debrief to determine guidelines for the investigation and next steps for escalation. If you choose to disclose your name, you will hear follow up within 30 business days.

WHO ARE THE MEMBERS OF THE WHISTLEBLOWER COMMITTEE THAT WILL MANAGE THE REPORT?

• Core Spaces Founder and Chief Sustainability Officer
• Executive Managing Director, President
• Chief People Officer
• Chief Financial Officer
• Chief Accounting Officer

Additional questions? Don't hesitate to reach out to us at whistleblower@corespaces.comwhistleblower@corespaces.com