The Jewish Federation of Detroit (Federation) requires all employees to observe the highest standard of business and personal ethics in the conduct of their duties and responsibilities. As representatives of Federation, employees must practice honesty and integrity in fulfilling responsibilities and comply with all applicable laws and regulations. Unlawful or unethical conduct of any type will be grounds for appropriate discipline, up to and including termination.
This Whistleblower Policy establishes procedures that ensure Federation’s board members, officers, employees and other key individuals can report good-faith suspicions of illegal, unethical, or other inappropriate activity without fear of retaliation. Federation will promptly and confidentially investigate all reported instances of possible fraudulent or dishonest activities and will pursue legal remedies available under the law.
Reporting and Deterrence:
Any employee, board member, or other key individual who becomes aware of any suspected unlawful or unethical behavior should report the matter. Reports can be made to an employee’s supervisor, Human Resources Director, Chief Financial Officer, Chief Executive Officer, Audit Committee Chair, or by utilizing Ethicspoint, an independent and confidential third party reporting organization. Ethicspoint can be contacted at 1-800-508-1279 or at www.ethicspoint.com. Reports may be made on an anonymous basis.
Any employee who files a report of suspected unlawful or unethical conduct in good faith will not be adversely affected in terms and conditions of employment and will not be retaliated against or discharged because of the complaint. Nor will Federation tolerate retaliation against any employee who, in good faith, cooperates in the investigation of a complaint. Anyone who engages in such retaliatory behavior will be subject to appropriate discipline, up to and including termination.
Reports to the Audit Committee:
The Chairs of the Audit and Finance Committees will receive copies of all complaints. A summary of complaints and their disposition will be presented to the full Audit Committee on an annual basis.
Posting of Policy:
The Whistleblower Policy will be included in the Employee Handbook, posted in common areas of the workplace and will be reviewed with staff and the Board of Directors on an annual basis.
Definitions:
Unlawful or unethical behavior includes, but is not limited to, any of the following conduct:
- Fraud or abuse;
- Conflict of interest, including engaging in any activity for remuneration which conflicts directly or indirectly with the business of the Federation or any Agency affiliated with the Federation (Agency);
- Misappropriation or theft of money or property belonging to the Federation, an Agency, or Agency client, including information in the Federation or any Agency’s computer data base;
- Deficiencies in, or non-compliance with, Federation’s internal accounting controls;
- Harassment or discrimination;
- Aiding or abetting any other employee or person in unlawful or unethical behavior, including failure to report obvious unlawful or unethical behavior;
- Bribery or attempted bribery of an employee or agent of any entity with whom Federation is doing business or is seeking to do business, or who is seeking business from Federation;
- Soliciting or accepting money or any thing of value from any person or entity doing business, or seeking to do business, with the Federation or any Agency,
- Spending or expending Federation or Agency funds for personal use;
- Unauthorized computer access or computer use;
