This is to advise you that on February 23, 2009, the Jewish Social Services of Madison adopted a “Whistleblower Policy” that sets forth (1) certain specific actions that are explicitly prohibited and (2) procedures that employees may follow if there is reason to believe that any laws are being violated.
1.1 Prohibited Actions
Commission of any of the following acts may lead to immediate disciplinary action, including but not limited to, termination of employment, and may also subject the offender to criminal liability:
- Intentionally destroying, altering, mutilating, concealing, covering up, falsifying, or making a false entry in any records that may be connected to a matter within the jurisdiction of a federal agency or bankruptcy proceeding, in violation of federal or state law or regulations.
- Intentionally altering, destroying or concealing a document, or attempting to do so, with the intent to impair the document’ availability for use in an official proceeding or otherwise obstructing, influencing or impeding any official proceeding, in violation of federal or state law or regulations.
- Fraudulently influencing, coercing, manipulating, or misleading any independent public accountant engaged in the performance of an audit of the financial statements of the JSS for the purpose of rendering such financial statements misleading.
- Discharging, demoting, suspending, threatening, harassing, discriminating or retaliating in any manner against any employee, because of any lawful act by that employee who:
- Provides information to or assists in any investigation by the JSS or by Congress or by any federal agency;
- Files or assists in any action alleging a violation of federal or state law or regulations; or
- Knowingly takes any action harmful to any person for providing truthful information to a law enforcement officer relating to the possible commission of a federal, state or local offense.
1.2 Reporting of Concerns or Complaints
JSS is committed to taking action to prevent problems and improper conduct. JSS urges employees and others to come forward with any such information, without regard to the identity or position of a suspected offender. Such information should be reported immediately to the President of any officer of JSS as provided in Section 1.4
JSS will not permit any negative or adverse actions to be taken against any employee or individual who in good faith reports a possible violation of law, including any concerns regarding questionable accounting or auditing matters, even if the report is mistaken, or against any employee or individual who assists in the investigation of a reported violation. Retaliation in any form will not be tolerated. Any act of alleged retaliation should be reported immediately to the President or any officer of JSS as provided in Section 1.4, complaints will be promptly investigated.
Knowingly false accusations or reports will be treated as a violation of this policy, and immediate discipline, up to and including termination, may result.
1.4 How to Report Concerns or Complaints
Employees may communicate suspected violations of law or other fiscal wrongdoing, including any concerns regarding questionable accounting or auditing matters (including deficiencies in internal controls) or alleged retaliation by calling or sending a letter to the President or any officer of JSS. In order to be better able to respond to any information or complaint, we would prefer that you identify yourself and provide your telephone number and other contact information when you make the report. You may be assured that any information will be treated with utmost confidence. However, if you wish to remain anonymous, it is not necessary that you give your name or position in any notification.
Whether you identify yourself or not, in order that a proper investigation can be conducted, please provide as much information as you can, sufficient to facilitate a thorough investigation, including where and when the incident occurred, names and titles of the individuals involved, and as much other detail as you can.
A Few Examples of What to Report
Accounting and Auditing Matters
The unethical systematic recording and analysis of JSS’ business and/or financial transactions. Examples included misstatement of contributions, expenses, assets and/or misapplications of generally accepted accounting principles and wrongful transactions.
Conflicts of Interest
A situation in which an employee has a private or personal interest sufficient to appear to influence the objective exercise of his/her official duties. An example is having one’ relative work in a company in which the individual controls JSS’ business and this was not disclosed to and approved in advance by JSS.
Falsification of Contracts, Reports or Records
This consists of altering, fabricating, falsifying or forging all or any part of a document, contract or record for the purpose of gaining an advantage or misrepresenting the value of the document, contract or records.
Any intentional wrongdoing on the part of a JSS employee that is a deliberate violation of law or fiscal policy.
JSS will treat all communications under this Policy in a confidential manner, except to the extent necessary (1) to conduct a complete and fair investigation, or (2) for review of JSS operations by JSS’ Board of Directors, its Audit Committee, the independent public accountants, JSS’ counsel, or any governmental agency.