WESTCHESTER REFORM TEMPLE
Whistleblower Policy
I. PURPOSES
The mission of Westchester Reform Temple (“WRT”) is to foster the perpetuation of the Jewish people and to cultivate a love of our Jewish heritage: God, Torah and Israel. In part, we hope to realize this through a commitment to Jewish values which encourage honest, ethical and lawful conduct, full, fair, accurate, timely and transparent disclosure in all public communications, and compliance with applicable laws, rules and regulations. In furtherance of these commitments, all Trustees, Officers, employees and volunteers of WRT (each, a “Covered Person” or “you”) must act in accordance with all applicable laws and regulations, and within the policies of WRT at all times, and assist in ensuring that WRT conducts its business and affairs accordingly.
This Whistleblower Policy (this “Policy”) (a) establishes procedures for the reporting and handling of concerns regarding action or suspected action taken by or within WRT that is or may be unlawful, fraudulent or in violation of any policy of WRT, as well as any other matter that could cause serious damage to WRT’s reputation (each, a “Concern”), and (b) prohibits retaliation against any Covered Person who reports a Concern in good faith.
By appropriately responding to Concerns, we can better support an environment where compliance is valued and help ensure that WRT is meeting its ethical and legal obligations and its mission.
II. WHEN TO RAISE A CONCERN
You have an affirmative duty to disclose to and seek guidance from an appropriate supervisor or manager if you believe any Covered Person or other person associated or doing business with WRT has engaged, is engaging, or may engage in any unlawful or unethical behavior, or has violated, or may violate any law, regulation or policy of WRT. Such reportable activity may include, for example, financial wrongdoing (including circumvention of internal controls or violation of the accounting policies of WRT), fraud, harassment, or any other unlawful, unethical or proscribed conduct. While Concerns may be submitted at any time, you should report a Concern as soon as reasonably possible after becoming aware of the matter.
III. HOW TO RAISE A CONCERN
Concerns may be submitted either in writing or orally. No form is required to submit a Concern, but you are encouraged to provide as much information and detail as possible so that the Concern can be properly investigated. A Concern may be submitted:
To the Executive Director of WRT as administrator of this Policy (the “Policy Administrator”) at execdirector@wrtemple.org, tel. no. 914.723.7727;
By discussing it with a supervisor or manager, who will in turn forward the Concern to the Policy Administrator or the President of WRT for review where appropriate; or
In writing (including by e-mail) to the President at president@wrtemple.org, who will in turn forward the Concern to the Policy Administrator for review where appropriate.
In the event a Concern involves or implicates the Policy Administrator or the President, the Policy Administrator or the President, as the case may be, will promptly recuse himself or herself from the investigation and inform the person not so involved or implicated in writing. Such other person may investigate such Concern or appoint an impartial professional (i.e., an attorney or accountant with experience in such matters, including a member of WRT if in the judgment of such person appointing a member of WRT is not unreasonable under the circumstances) to investigate and report on the Concern following the procedures set forth in Sections IV and V of this Policy. If the Concern involves or implicates both the Policy Administrator and the President they will promptly recuse themselves and so advise any member of the Executive Committee of WRT (“Executive Committee”) not so involved or implicated. Such Executive Committee member shall then proceed to investigate and report on the matter in the manner set forth in this Policy.
Concerns may be raised anonymously; however, anonymous reporting of a Concern may limit the ability of the Policy Administrator or other person to investigate the matter fully. Also, any individual reporting his or her involvement in a Concern shall not satisfy his/her obligation under this Policy by reporting such violation anonymously.
IV. PROCEDURES FOR RECEIVING AND REVIEWING CONCERNS
Any supervisor, manager, or other person receiving a Concern should contact the Policy Administrator (whose contact information is provided in Section III above), who will coordinate further action.
The Policy Administrator will assess each Concern on a preliminary basis to determine to what extent an investigation into the Concern is required, and will direct all aspects of the investigation of any Concern. All investigations will be conducted in a confidential and sensitive manner, so that information will be disclosed only as needed to facilitate review of the investigation materials or otherwise as required. Neither the person who is the subject of a Concern nor a member of the Board of Trustees who is an employee of WRT may participate in any Board or committee deliberations or voting relating to administration of the Policy, or be present at or participate in Executive Committee deliberations or vote on the matter of Concern, provided that nothing in this Section shall prohibit the Executive Committee from requesting that the person who is subject of a Concern (including a Board member who is an employee, if such is the case) present information as background or answer questions at an Executive Committee meeting prior to the commencement of deliberations or voting relating thereto. You must cooperate as necessary in connection with any such investigation. Following an investigation by (or overseen by) the Policy Administrator, the Executive Committee and/or Board of Trustees shall take all actions necessary and appropriate, if any, with respect to a Concern.
V. RECORDS OF CONCERNS AND INVESTIGATION REPORTS
The Policy Administrator (or the Executive Committee or such other person not the subject of the Concern as the Executive Committee shall appoint in the event the Concern involves the Policy Administrator) will maintain a written record of all Concerns, summarizing in reasonable detail for each Concern: the nature of the Concern (including any specific allegations made and the persons involved); the date of receipt of the Concern; the current status of any investigation into the Concern and information about such investigation (including the steps taken in the investigation, any factual findings, and the recommendations for corrective action); and any final resolution of the Concern. The Policy Administrator (or the Executive Committee or such other person who performed the investigation) will maintain the confidentiality of the detailed record of the investigation and provide information only to those individuals associated with or retained by WRT with respect to such matter needing to know such information. Notwithstanding the foregoing, a summary of the report may be distributed to the Executive Committee in advance of each regularly scheduled Executive Committee meeting.
VI. CONFIDENTIALITY
All Concerns received will be treated confidentially and/or anonymously, as applicable, to the extent reasonable and practicable under the circumstances.
VII. NO RETALIATION AGAINST WHISTLEBLOWERS
It is WRT’s policy to encourage the communication of bona fide Concerns relating to the lawful and ethical conduct of WRT’s operations. It is also the policy of WRT to protect those who communicate bona fide Concerns from any retaliation for such reporting. No Trustee, Officer, employee or volunteer of WRT, who in good faith reports any Concern or assists in an investigation of, or the fashioning or implementation of any corrective action or response made in connection with, any Concern, shall suffer intimidation, harassment, discrimination or other retaliation or, in the case of employees, adverse employment consequence. Any person who violates this prohibition against retaliation will be subject to appropriate disciplinary action, which may include termination of employment or other relationship with WRT.
VIII. POLICY DISTRIBUTION
A copy of this Policy will be distributed to each Covered Person promptly following the adoption of or any amendments to this Policy, and at such time as a person becomes a Covered Person. For purposes of this Section, inclusion of the Policy in the WRT Employee Manual distributed to all WRT employees, posting the Policy on WRT’s website or at WRT’s offices in a conspicuous location accessible to employees and volunteers, will satisfy this distribution requirement.
IX. POLICY ADOPTION AND OVERSIGHT
The Executive Committee is responsible for providing oversight of the adoption and implementation of, and compliance with, this Policy. Only independent Officers of WRT satisfying the definition of “independence” pursuant to applicable law are permitted to participate in any Executive Committee deliberations or vote on matters relating to this Policy.
NOTE: Any Concern reported to WRT pursuant to this policy does not satisfy any or all obligations a person may have as a “mandatory” or “mandated” reporter under applicable Federal, State, and local law.
This Whistleblower Policy was adopted by the Board of Trustees of WRT on June 19, 2018