The Jewish Federation of Greater New Orleans (Federation) requires board members, committee members, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities and comply with all applicable laws and regulatory requirements.

Reporting Responsibility: The Federation intends to adhere to all laws and regulations that apply to the Federation.  The underlying purpose of this policy is to support the Federation’s goal of legal compliance.  Any concerns about possible fraudulent or dishonest conduct or other violations of any applicable laws and regulatory requirements should be reported.  A board member or committee member should present his/her/their concerns to the Chair of the Board or Vice-Chair of the Board.  If a board or committee member is not comfortable speaking with the Chair or Vice-Chair of the Board or is not comfortable with their response, however, the board member or committee member should speak with the Chief Executive Officer.  An employee of the Federation should present his/her/their concerns to the CEO.  If an employee is not comfortable speaking with the CEO or is not comfortable with the CEO’s response, however, the employee should speak with the Chair, a Vice-Chair of the Board, or another member of the Federation’s management team.  

No Retaliation:  The Federation will use its best efforts to protect a whistle-blower from retaliation.  An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.  This Whistle-Blower Policy is intended to encourage and enable persons to raise serious concerns within the Federation before seeking resolution outside the Federation.  Whistle-blowers who believe that they have been retaliated against may file a written complaint with the CEO or Board Chair.  Any complaint of retaliation will be promptly, thoroughly, and objectively investigated, and appropriate corrective measures will be taken if the allegation of retaliation is substantiated.  This protection from retaliation is not intended to prohibit supervisors from taking action, including disciplinary action, within the usual scope of their duties and based on valid performance-related factors.

Compliance Officer: The Compliance Officer is responsible for investigating and resolving all employee complaints and allegations concerning violations of any ethical or legal principles or code applicable to the Federation and its employees.  The CEO will act as the Compliance Officer for employee complaints regarding other employees.  The Board Chair or his or her designee will take on the Compliance Officer role if the complaint involves the CEO.  Should the complaint involve both the CEO and Board Chair, outside legal counsel or another appointee will carry out the function of the Compliance Officer.  

Accounting and Auditing Matters:  The Audit Committee of the Board of Trustees shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing.  The Compliance Officer shall immediately notify the Audit Committee of any such complaint and work with the Audit Committee until the matter is resolved.

Requirement of Good Faith:  Anyone filing a complaint concerning a violation or suspected violation of the law or regulatory requirements must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.  The Federation will view as a serious disciplinary offense any allegations that prove to be unsubstantiated and to have been made maliciously or with knowledge of their falsity.

Confidentiality:  Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously.  Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations:  The Compliance Officer or the person responsible for carrying out the Compliance Officer’s role with respect to a reported or suspected violation will acknowledge receipt of the reported or suspected violation, by letter or e-mail, to the complainant within five (5) business days of receiving the complaint.  All reports will be promptly, thoroughly, and objectively investigated, and appropriate corrective action will be taken if warranted by the investigation.