Policy and Procedures for Ethical and Financial Complaints

Adopted by the Audit Committee, March 20, 2008

Adopted by the CAMA and CAMF Boards of Directors September 25, 2008

Revised September 24, 2009

A. Policy for Ethical and Financial Complaints

The Crocker Art Museum - the Crocker Art Museum Association and the Crocker Art Museum Foundation - (jointly herein referred to herein as "MUSEUM") and its Board of Directors is committed to achieving the highest standards of ethical conduct and institutional integrity. It seeks to comply with all applicable financial laws and regulations and exercises utmost care in accounting and auditing practices.

It is the MUSEUM's policy to investigate all complaints relating to ethical or financial misconduct ("Complaints") promptly and discreetly, for the purpose of preventing, confirming and/or correcting the violation. MUSEUM accepts Complaints from all sources. It encourages individuals who submit Complaints to identify themselves to allow for the best possible investigation, with the assurance that all matters will be handled in strictest confidence. However, Complaints may be made anonymously and in such circumstances the Organization will not make an effort to discern the identity of the complainant.

MUSEUM's Board Members and employees have a special, affirmative duty to report Complaints. If a Board Member or employee suspects that he or she has violated the MUSEUM's ethical or financial provisions, or observes, learns or in good faith believes it is possible that a colleague or other person has done so, he or she must report the violation immediately.

MUSEUM prohibits retaliation against an employee and any other persons who, in good faith, makes or supports a Complaint, states he or she will make a Complaint, or provides assistance to an investigation under this policy, even if the Complaint is ultimately determined to be without merit. However, employees who make Complaints or provide information that they know to be false, or do not reasonably believe to be true, may be subject to disciplinary action, up to and including termination of employment.

In support of this Policy (hereafter, the "Policy for Ethical and Financial Complaints"), the Audit Committee has established certain procedures for the submission, investigation, resolution and retention of Complaints. These Procedures (hereafter, the "Procedures for Ethical and Financial Complaints") are set forth below.

B. Procedures for Ethical and Financial Complaints

1. Scope

These Procedures apply only to Complaints of a financial and ethical nature. They do not apply

to matters that are properly the domain of the Human Resources Department, such as labor, employment or harassment concerns.

* Legitimate Complaints include the following examples:

* Financial fraud, including bank fraud, or fraudulent statements to any governmental entity; and

* Intentional misstatements, misrepresentations, deception, or fraud in the preparation, review or audit of any financial statement or report of the MUSEUM; and

* Significant deficiencies in or intentional noncompliance with the MUSEUM'S internal accounting controls; and

* Misappropriation of MUSEUM assets or embezzlement; and

* Violations of the MUSEUM's code of ethics, including prohibitions against self-dealing, misuse of MUSEUM resources, and acceptance of gifts that exceed the acceptable value; and

* Violations of applicable laws, rules and regulations related to accounting, internal accounting controls, auditing and financial matters; and

* Retaliation against individuals who submit Complaints in good faith

2. Submission Process

(a) Designated Recipients. Complaints may be submitted by any person, as follows:

(i) By speaking directly to the MUSEUM's General Counsel, as designated by MUSEUM from time to time in person or writing to him/her at the following address:

Russell Austin

Murphy Austin Adams Schoenfeld LLP

304 S Street

Sacramento, CA 95811

(ii) By speaking directly to the present President of the Board of MUSEUM in person or in writing.

(b) Alternative Recipient. If a Complaint relates to conduct by the General Counsel, the President of the Board of Directors shall substitute for the General Counsel for all functions under this Policy and Procedure. If a Complaint relates to conduct by the General Counsel and the President of the Board of Directors, the Chair of the Audit Committee and the Museum Director shall substitute for all functions under this Policy and Procedure.

(c) Managerial Knowledge. If a Complaint from an employee is made directly to a manager, whether received orally or in writing, the manager shall promptly report it to the General Counsel while noting all requests for confidentiality.

3. Investigation

If a Complaint is made directly to any member of the Audit Committee, he or she will promptly report the information to the General Counsel. In all circumstances, unless otherwise directed by the Audit Committee Chairman, the General Counsel will review each Complaint received and, in collaboration with appropriate members of management and/or, as the case may be, the Audit Committee, determine an appropriate manner of investigation. In addition, the General Counsel may consult or request assistance from members of the Board, management or staff believed to have appropriate expertise or information to assist in the investigation or disposition of the Complaint. The General Counsel may also engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.

In determining the manner in which a Complaint should be investigated, the General Counsel shall consider the following factors:

(a) the seriousness or materiality of the alleged wrongdoing.

(b) the alleged wrongdoer.

(c) the credibility of the allegation of wrongdoing.

All facts surrounding the allegation should be considered, including but not limited to whether similar allegations have been made previously.

The investigation shall be conducted with all appropriate confidentiality, although the subject or subjects of the Complaint may be notified of the investigation in the General Counsel's discretion, as the circumstances require.

4. Resolution

Upon the conclusion of the investigation, the General Counsel and appropriate members of management and/or, as the case may be, the Audit Committee, will determine corrective measures and a schedule for implementation. Such corrective measures may include, for example, employment sanctions (including termination), discussions with law enforcement or governmental bodies, and the implementation of new auditing, accounting or financial policies. If the determination is that no corrective measures are necessary, the General Counsel will report the matter to the Audit Committee consistent with section 5 of these Procedures. If the General Counsel is aware of the identity of the complainant, the General Counsel may inform that person of the resolution if appropriate to do so, in the General Counsel's discretion. The subject or subjects of the Complaint may be notified of the resolution in the General Counsel's discretion, as the circumstances require. The General Counsel shall prepare a written report stating the conclusion of the investigation including corrective actions if applicable, which report shall be submitted to [the Executive Committee][or][Standing Committee appointed for such matters]. That Committee shall then report the outcome to the Board of Directors.

5. Reports to Audit Committee

At all regularly-scheduled Audit Committee meetings, and whenever else the Audit Committee may direct, the General Counsel shall report to the Audit Committee on the status of all open Complaints. The report shall list (a) all new Complaints and Complaints still open at the time of the report, regardless of when made (including minor Complaints or Complaints that are ultimately found to be without merit); and (b) the results of all investigations not previously reported; and (c) the disposition of all Complaints not previously reported.

The Audit Committee shall review, and have oversight responsibility for, all Complaints, investigations and resolutions.

6. Non-Retaliation

MUSEUM, or its Board of Directors, committee members or the managers and/or employees will not knowingly retaliate or take any action harmful to any person, including interference with lawful employment or livelihood, for making a Complaint in good faith pursuant to this policy or providing assistance to investigation law enforcement officers, governmental bodies, or persons with supervisory authority over the Complaint. Retaliation against an individual for the aforementioned acts is a serious violation of these Procedures and anyone who so retaliates may be subject to disciplinary action, termination of employment or Board position, civil action and criminal penalties.

7. Protection and Retention of Records

Records relevant to a Complaint shall be assembled and secured as soon as possible to protect against corrupt alteration, mutilation, destruction or concealment of any record, document or object with the intent to impair its integrity or availability in the investigation or in any official government proceeding. The retention period shall be seven years for all records relating to receipt, investigation, and disposition of a Complaint.

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About the Museum

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Resources/Information

In 1868, Judge Edwin B. Crocker purchased the property and existing buildings on the corner of Third and O Streets. He then commissioned Seth Babson (1830-1908), a talented local architect, to redesign and renovate the home into a grander, Italianate mansion. In addition, Crocker asked Babson to design an elaborate gallery building that would sit adjacent to the mansion and display the family's growing art collection.

Babson saw the home and gallery as an integrated complex, unique in design and demanding the finest materials. The gallery building included a bowling alley, skating rink, and billiards room on the ground floor; a natural history museum and a library on the first floor; and gallery space on the second floor. Completed in 1872, the Crocker family mansion and art gallery are considered the masterpieces of Babson's career.

The family mansion went through several uses and reconstructions until a 1989 renovation restored the historic façade and created a modern gallery interior. The original buildings, now connected, as well as the cast concrete Herold Wing addition of 1969, were renamed the Crocker Art Museum in 1978. The gallery building is a California Historical Landmark and listed in the National Register of Historic Places.

In 2000, the Crocker appointed a selection committee comprised of elected officials, community leaders, CAMA Board members, City staff, and potential donors to search for an architect that would lead the Museum through master planning. After a comprehensive review of all of the major museum architects in the world, Gwathmey Siegel & Associates Architects (GSAA) was unanimously chosen to guide the process because of their design aesthetic and past experience.

GSAA designed the expansion of the Crocker after conducting a thorough master planning process. Many voices from the community were involved in a collaborative process to ensure that the new building and the internal reconfiguration of the existing structures would work together as a whole.

On October 10, 2010, the Crocker opened the 125,000-square-foot Teel Family Pavilion. The classic, contemporary design of the Pavilion complements the historic structures. The New Crocker Art Museum: The Making of a Masterpiece takes an in-depth look behind the scenes of the fundraising process, the design and construction of the new facility, and the building and exhibition of the Crocker's collection. Produced, directed, and edited by Laurence Campling, the DVD is available for purchase at the Museum Store and may be viewed here.

The expansion more than tripled the Museum's size, enhancing its ability to serve as a cultural and educational resource for Sacramento and the region's many visitors. For the first time in the Museum's history, there are dedicated gallery spaces for all collecting areas. The expansion also enabled the dedication of the historic building's entire first floor as the Museum's Education Center, including four studio classrooms, three Student & Community Exhibition spaces, an expanded Gerald Hansen Library, the Early Childhood Resource Depot, and Tot Land. Additional amenities made possible by the Teel Family Pavilion include the Setzer Foundation Auditorium, the Crocker Courtyard, the Cemo Meeting Center, the Anne and Malcolm McHenry Works on Paper Study Center, and the Crocker Cafe.

In 1869, Judge Edwin B. and Margaret Crocker assembled a collection of more than 700 paintings and 1,300 master drawings during their family's 1869-71 trip to Europe. Following this sojourn, the Crockers acquired numerous paintings by contemporary Californian artists, forming the core of a Californian collection that has evolved until the present day and is now considered one of the finest in the United States. The collection was installed in the couple's newly-built gallery building by 1873.

Although the Crockers frequently opened the gallery building to the public, it remained a privately held collection until Margaret Crocker presented the building and collection to the City of Sacramento and the California Museum Association (now the Crocker Art Museum Association) in 1885.

The Association continued the collecting emphases of its founders. In 1889, David Lubin, a member of the first Board of Directors of the California Museum Association, donated marble sculptures, some of which are located in the niches of the grand staircase in the Museum’s lobby. Thus began a cycle of giving which grew the original private art collection to its current size and scope. Jennie Crocker Fasset's donation of Korean ceramics in 1927 formed the basis of both an Asian art collection and a collection of ceramics that now represents myriad eras and cultures. Acquisitions of paintings by American artists in the 1970s enhanced this collection area, and other gifts came in the form of prints and photographs. More recent donations of African and Oceanic art established a new collecting focus as these works, along with thousands of others acquired in the past decade, have enriched every area of the Museum's holdings.