Lutheran Hour Ministries

LHM Policies

Privacy Policy

Lutheran Hour Ministries is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.

This Website takes every precaution to protect our users' information. All of our users' information is restricted in our offices. Only employees who need the information to perform a specific job are granted access to personally identifiable information. Additionally, our Website is hosted by a company that employs the latest technological security measures to protect data.

Monitoring Of Access. Access to this Web site is monitored. The requesting URLs, the machine originating the request, and the time of the request are logged for access statistics and security purposes. Use of this Web site constitutes consent to such monitoring.

If we decide to change our privacy policy, we will post those changes on our home page so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

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Whistleblower Policy

Official BOG Version April 28, 2007

General

Lutheran Hour Ministries (LHM) Board Policy Manual's Governing Principles and Integrity and LHM's Employee Handbook require directors, officers, volunteers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of LHM, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Responsibilities

It is the responsibility of all directors, officers, volunteers and employees to comply with LHM's Policies and to report violations or suspected violations in accordance with this Whistleblower Policy.

The Compliance Officer for LHM shall be an outside mediation source determined by the Executive Committee of the Board of Governors in conjunction with the Executive Director of LHM. If the grievance is against an officer(s) of the Executive Committee or the Executive Director of LHM, this person shall withdraw from this selection process. The Board's Executive Committee serves as the Audit Committee for LHM.

No Retaliation

No director, officer volunteer, or employee who, in good faith, reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequence. An employee, who retaliates against someone who has reported a violation in good faith, is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within LHM prior to seeking resolution outside LHM.

Reporting Violations

The Code of Ethics addresses LHM's open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee's supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor's response, you are encouraged to speak with someone in the Human Resources Department or anyone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code of Ethics to LHM's Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable with following LHM's open door policy, individuals should contact the Compliance Officer directly.

Compliance Officer

LHM's Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code of Ethics and, at his/her discretion, shall advise the Executive Director and/or the audit committee. The Compliance Officer has direct access to the audit committee of the board of directors and is required to report to the audit committee at least annually on compliance activity.

Accounting and Auditing Matters

The audit committee of the board of directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the audit committee of any such complaint and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the Code of Ethics must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code of Ethics. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense and may result in disciplinary action, up to and including termination.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

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