Whistleblower Policy

Columbia/Barnard Hillel Inc.
Whistleblower Policy

The Columbia/Barnard Hillel Inc. (the “Organization”) is committed to lawful and ethical behavior in all of its activities and has adopted a Code of Conduct (the “Code”) that requires directors, officers, employees and volunteers providing substantial services (hereinafter “volunteers”) to comply with all applicable laws and regulations and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. It is the responsibility of all directors, officers, employees and volunteers to report violations or suspected violations of the Code in accordance with this Whistleblower Policy (the “Policy”). No director, officer, employee or volunteer who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequence.

Code of Conduct
Pursuant to the Columbia/Barnard Hillel’s Code of Conduct, the directors, officers, employees and volunteers of the Organization are expected to adhere to high standards of ethical conduct. Although it is impossible to describe all conduct that is to be addressed, this Code specifically requires that the behavior of directors, officers, employees and volunteers exhibit the following:
1. Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
2. Full, fair, accurate, and timely disclosure of relevant facts in all reports and documents dealing with matters of program services, governance and business administration.
3. Compliance with all applicable governmental laws, rules and regulations.
4. Prompt internal reporting of code violations to an appropriate person or persons within the organization.
5. Personal accountability for adherence to the Code.

Reporting Violations
Employees and volunteers who suspect that the Code of Conduct has been violated shall report their concerns to someone who can address them properly. In most cases, the supervisor of an employee or volunteer is in the best position to address an area of concern. Where the reporter is not comfortable speaking with a supervisor or is not satisfied with a supervisor’s response, he/she shall speak with someone in the Human Resources Department, anyone in management, or the Compliance Officer directly. If an employee or volunteer reports a violation or suspected violation to his/her supervisor, a Human Resources Department employee, or management, such person receiving the complaint shall in turn report to the Compliance Officer, who is designated to administer this Policy. Directors and officers shall report suspected violations to the Compliance Officer directly.

Compliance Officer
The director acting as Chair of the Audit Committee shall also serve as the Compliance Officer of the Organization. The Compliance Officer must, as soon as possible, report to the Audit Committee any complaints he/she receives concerning suspected violations of the Code of Conduct. In conjunction with the Audit Committee, the Compliance Officer is primarily responsible for investigating and resolving all such complaints, and will ensure that they are handled in a timely and sensitive manner. In addition to reporting any individual complaints to the Audit Committee as they are received, the Compliance Officer shall also report to the Audit Committee at least annually on overall compliance activity.

Acting in Good Faith
Anyone who files a complaint concerning a suspected violation of the Code of Conduct must have reasonable grounds for believing the information disclosed is true and correct. Unsubstantiated allegations that prove to have been made maliciously or without factual basis will be viewed as a serious disciplinary offense.

Reports may be submitted on a confidential basis or anonymously. A complainant’s request for confidentiality and/or anonymity in reporting violations or suspected violations will be respected to the extent possible, consistent with the need to conduct an adequate investigation. The confidentiality of reported information will be maintained by channeling reports directly to the Compliance Officer and, in turn, to the Audit Committee, and disclosing information to other directors and employees only as needed to fully investigate a report.

Handling of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

No Retaliation
No director, officer, employee or volunteer who in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequences.

A copy of this policy must be distributed to directors, officers, employees and volunteers.