Whistleblower Policy
Described below is UJA-Federation’s Whistleblower Policy (the “Policy”), as approved by UJA-Federation’s Ethics & Conflicts Committee and posted on the organization’s website. The Policy describes the organization’s philosophy of encouraging employees and volunteers to make good faith reports of possible violations of law or infractions of rules or organizational policies, and to raise any concerns about such matters, confidentially and without fear of retaliation. In addition, the Policy provides a procedure for reporting such complaints by telephone or email, either to the organization’s appointed ombudspersons or to an outside service, on a completely anonymous and confidential basis. UJA-Federation is committed to giving its employees a way to express concerns regarding suspected violations of law or organizational rules or policies by UJA-Federation personnel in a confidential manner, without any fear of reprisal. If you have any questions about the Policy, please call the Vice President of Human Resources or the General Counsel and Chief Compliance Officer.
Introduction
UJA-Federation is committed to the highest standards of ethical conduct. Given UJA-Federation’s mission and responsibilities, which literally span the globe, all employees, Board members and lay leaders have an obligation to preserve the organization’s reputation and standing, in our community and beyond, to uphold the public trust, and to act in an ethical and lawful manner. UJA-Federation requires its employees, Board members and lay leaders (“UJA-Federation personnel”) to observe high standards of business and personal ethics, and to comply with all applicable laws and regulations, in the conduct of their duties and responsibilities for the organization. Accordingly, UJA-Federation has established an Ethics and Conflicts Committee (formerly known as the Standards and Conflicts Committee), so that potential ethical issues can receive the attention they deserve. UJA-Federation’s reputation for acting in accordance with the highest standards of ethical conduct is one of its most valuable assets. The assistance of all employees, Board members and lay leaders in preserving this asset is both expected and sincerely appreciated.
The Whistleblower Policy
As part of its overall commitment to the highest standards of ethical conduct, UJA-Federation has established a Whistleblower Policy (the “Policy”). This Policy has been developed and implemented to encourage employees and volunteers to make good faith reports of possible violations of law or infractions of rules or organizational policies by any UJA-Federation personnel, and to raise any concerns they may have about such matters, confidentially and without fear of retaliation, within UJA-Federation prior to seeking a resolution outside the organization. Reports also may be made through this process regarding inappropriate acts or possible breaches of law or established policy by entities with whom UJA-Federation does business, such as vendors or service providers, including investment managers or consultants.
PLEASE NOTE THAT THIS WHISTLEBLOWER POLICY APPLIES TO UJA-FEDERATION AND ITS EMPLOYEES, BOARD MEMBERS AND LAY LEADERS. WHILE THIS POLICY DOES NOT APPLY TO GRANTEE AGENCIES, WHICH HAVE THEIR OWN POLICIES AND PROCEDURES, IF UJA-FEDERATION RECEIVES A REPORT ABOUT POSSIBLE VIOLATIONS AT A GRANTEE AGENCY. WE WILL APPRISE THE AGENCY OF SUCH REPORT AND INQUIRE ABOUT STEPS TAKEN TO ADDRESS THE COMPLAINT.
Types of matters that should be reported under the Whistleblower Policy include suspected fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, abuse or misuse of UJA-Federation’s resources or assets, conflicts of interest, suspected compliance or ethics-related issues, concerns or violations, or suspected wrongdoing.
The Whistleblower Policy reporting mechanisms may also be used to report human resources issues, personal problems with co-workers or managers, or matters of workplace discrimination or harassment. However, these types of matters are more typically handled using the “Internal Complaint Procedures” outlined in the UJA-Federation Employee Policy Manual.
Confidentiality and Non-Retaliation
In order to encourage UJA-Federation employees and volunteers to come forward with any good faith report of suspected illegal or unethical behavior on the part of any UJA-Federation personnel, all reports made through the mechanisms established under the Whistleblower Policy will be treated as confidential to the utmost extent possible.
Reports may also be made anonymously, as described below.
Moreover, no person who makes a good faith report under the Whistleblower Policy may be subject to any form of retaliation, harassment or adverse employment action. Any employee who engages in any such retaliatory action is subject to serious disciplinary action, including possible termination of employment.
The Whistleblower Process
Any person who makes a report pursuant to the Whistleblower policy will be treated with dignity and respect.
Several avenues have been established to receive Whistleblower reports from particular sources, as described below. However, these avenues are in no way restrictive; a person making a report under the Whistleblower Policy may contact any of the following persons:
Reports from Members of the Board of Directors, Lay Leaders, and Members of the Public
The Chair of the Ethics and Conflicts Committee of UJA-Federation has been designated as the primary recipient of complaints of wrongdoing from members of the Board of Directors, lay leaders and members of the public. Currently, Don Bernstein serves as Chair of the Ethics and Conflicts Committee. Mr. Bernstein may be reached directly at (212) 450-4092 or at donald.bernstein@davispolk.com.
Reports from UJA-Federation Staff Members
Two persons have been designated as primary contacts to receive reports of wrongdoing from UJA-Federation staff members: UJA-Federation’s General Counsel and Chief Compliance Officer and UJA-Federation’s Vice President of People and Culture. Ellen Zimmerman serves as General Counsel and Chief Compliance Officer of UJA-Federation, and Sari Ferro serves as UJA-Federation’s Vice President of People and Culture. Ms. Zimmerman may be reached directly at (212) 836-1312 or 
. Ms. Ferro may be reached directly at (212) 836-1650 or 
.
Reports from All Sources to an Outside Organization
To ensure that any person wishing to make a good faith report in a confidential setting will feel assured of such confidentiality, UJA-Federation has retained an outside organization, ComplianceLine, that specializes in handling reports about perceived violations of law or organizational policies. Reports to this organization may be both anonymous and non-anonymous. Instructions as to making a report may be found at www.MyComplianceReport.com (enter the Access I.D. “UJA”) or by calling (888) 495-4351.
All persons receiving reports are responsible for investigating and resolving all reported complaints and allegations expeditiously, and will promptly contact the complainant to acknowledge receipt of the reported concern. If ComplianceLine receives the report, an investigation will be conducted internally by the appropriate person designated by the Chief Compliance Officer of UJA-Federation. All reports will be promptly investigated to the extent possible and appropriate corrective action will be recommended to UJA-Federation’s Ethics and Conflicts Committee, Audit Committee and Executive Committee, as and if warranted by such investigation. In addition, the Chief Compliance Officer will coordinate with the Chair of the Ethics and Conflicts Committee to report annually to the Executive Committee on all investigations.
Conclusion
The Whistleblower Policy has been established as part of UJA-Federation’s comprehensive effort to maintain the highest standards of ethical conduct. As described above, this Policy has been structured to encourage UJA-Federation’s employees and volunteers to come forward and report, in good faith, confidentially, and without fear of reprisal, any suspected violations of law or organizational rules or policies by UJA-Federation personnel.
Amended as of February 1, 2017 by the UJA-Federation Ethics and Conflicts Committee (formerly known as the Standards and Conflicts Committee).
