Vanguard Charitable requires trustees, officers, employees, contractors and vendors to observe high standards of business and personal behavior in the conduct of their duties and responsibilities.  The Whistle-blower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Vanguard Charitable can address and correct inappropriate conduct.  Employees of Vanguard Charitable Endowment Program (the “Program”) and others may submit complaints regarding the integrity of the Program’s accounting, auditing, and financial reporting controls and procedures to the Program, and/or regarding serious issues with conduct or the Program’s code of ethics, by submitting such complaints to the President. The Program shall promptly forward to the Audit Committee any such complaints that it has received. Employees and others may also submit such complaints directly to the Audit Committee on a confidential, anonymous basis.

All complaints shall be set forth in writing and forwarded to the Chair of the Audit Committee in a sealed envelope marked clearly as a confidential submission for the attention of the Audit Committee to the following address:

                  Chairperson – Audit Committee

                  c/o Ms. Beth Morales Singh

                  Vanguard Charitable Endowment Program Secretary

                  The Vanguard Group, Inc.

                  400 Devon Park Drive, V16

                  Wayne, PA  19087

Each complaint should indicate that it is being made pursuant to the “Whistle-blower Policy” adopted by the Audit Committee.  If the person submitting a complaint is not interested in being anonymous, he or she should consider including a telephone number at which he or she might be contacted if the Audit Committee deems it appropriate. Any such envelopes received by the Program Secretary shall be forwarded promptly and unopened to the Chair of the Audit Committee.

The Audit Committee will investigate each matter reported hereunder and take corrective and disciplinary actions, if appropriate. The Audit Committee may enlist employees of the Program and/or outside legal, accounting, or other advisors, as appropriate, to conduct any investigation of complaints pursuant to this policy. In conducting any investigation, the Audit Committee shall use reasonable efforts to protect the confidentiality and anonymity of the complainant.

The Program does not permit retaliation of any kind against employees or others for complaints submitted hereunder that are made in good faith.