Hebrew Free Loan Society Whistleblower Protection Policy
In keeping with the policy of maintaining the highest standards of conduct and ethics, the Hebrew Free Loan Society (“HFLS”) will investigate any suspected (i) fraudulent or dishonest use or misuse of HFLS resources or property, (ii) illegality or (iii) violation of any adopted policy of HFLS, in each case whether by staff, board members, consultants, or volunteers (“fraudulent or dishonest conduct”).
Staff, board members, consultants, and volunteers are encouraged to report suspected fraudulent or dishonest conduct (i.e., to act as “whistleblower”), pursuant to the procedures set forth below.
A person’s good faith concerns about possible fraudulent or dishonest conduct should be reported to his or her supervisor or, if suspected by a volunteer, to the staff member supporting the volunteer’s work. If, for any reason, a person finds it difficult to report his or her concerns to a supervisor or staff member supporting the volunteer’s work, the person may report the concerns directly to the CEO. If the concern about possible fraudulent or dishonest conduct involves the CEO, the person should report the concern to the HFLS Board President. Alternately, to facilitate reporting of suspected violations where the reporter wishes to remain anonymous, a written statement may be submitted to one of the individuals listed above, as appropriate.
Allegations made with reckless disregard for their truth or falsity.
An employee, consultant, or volunteer who informs a supervisor, the CEO, or the Board President, as appropriate in accordance with this policy, about an activity relating to HFLS which that person believes in good faith to be fraudulent or dishonest conduct.
Supervisors are required to report suspected fraudulent or dishonest conduct to the CEO. If the concern about possible fraudulent or dishonest conduct involves the CEO, the supervisor should report the concern to the HFLS Board President. Reasonable care should be taken in dealing with suspected fraudulent or dishonest conduct to avoid:
Due to the important yet sensitive nature of the suspected violations, effective professional follow-up is critical. Supervisors, while appropriately concerned about “getting to the bottom” of such issues, should not in any circumstances perform any investigative or other follow-up steps on their own. Accordingly, a supervisor who becomes aware of suspected misconduct:
All relevant matters, including suspected but unproved matters, will be reviewed and analyzed, with documentation of the receipt, retention, investigation, and treatment of the complaint. Appropriate corrective action will be taken, if necessary, and findings will be communicated to the reporting person and his or her supervisor. Investigations may warrant investigation by independent persons such as auditors and/or attorneys. Individuals making baseless allegations may be subject to disciplinary action by HFLS, and/or legal claims by individuals accused of such conduct.
HFLS will protect whistleblowers as defined below:
The Director of Finance & Administration shall administer this Policy and report to the Audit Committee as to its operation and implementation.