Institutional Integrity (Whistleblower)

The Jewish Theological Seminary of America ("JTS") has a responsibility to manage its resources wisely, consistent with the law and in accordance with the JTS's stated purposes.  JTS has put in place operating procedures and internal controls which are intended to enable JTS to conduct its operations in accordance with these obligations and to detect, deter or prevent improper activities.  However, intentional and unintentional violations of laws, regulations, policies and procedures may occur and may constitute improper or unlawful activities.

JTS has a responsibility to investigate any reports of improper or illegal conduct, and to take action where necessary to remedy a problem and prevent reoccurrence.  In certain circumstances JTS will report allegations of improper activities to the appropriate parties, and will also report the resolution of any investigation.  Investigations will be conducted with discretion and the information obtained made available only on a "need to know" basis.

The matters which should be reported under this policy include suspected fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, misuse of JTS assets or suspected regulatory, compliance or ethics related issues, concerns or violations. Violations of JTS's applicable human resources policies, problems with co-workers or managers or for reporting issues related to alleged employment discrimination or sexual or other form of unlawful harassment, all of which should be dealt with in accordance with JTS's Human Resources Policies or its Policy on Discrimination and Sexual Harassment.

JTS also has a responsibility to protect from retaliation employees who, in good faith, report suspected allegations of improper or illegal conduct at JTS or by JTS personnel.  It is the responsibility of every employee to report any suspected incidents of improper or illegal activity and violations of significant JTS policies and procedures.  An employee should also report any situation where the employee believes he or she has been directed to engage in conduct or activity which would result in a violation of law.  These reports should be factual and contain as much specific information as possible.

An employee should report these concerns promptly to JTS's General Counsel, Martin Oppenheimer, or another appropriate senior administrator.  If an employee is concerned about making a report, the employee may make the report anonymously but this often hampers the ability to conduct a full investigation.  Reports may be made orally to Mr. Oppenheimer at 212-678-8804, by email to him at maoppenheimer@jtsa.edu, or by placing a written report in his internal mailbox, Box No. 77.  In following up on a report, Mr. Oppenheimer may ask for additional information, so the employee should provide contact information.

An employee filing a complaint concerning a violation or suspected violation of the standards noted above must act in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of such standards. An employee who has made a protected disclosure in good faith or participates in an investigation of suspected conduct will not be subject to retaliation. In the event an employee believes retaliation is occurring, or the s/he is being pressured not to report improper or illegal activity, the employee should promptly advise the General Counsel or another senior administrator.  Anyone who engages in retaliation or acts to frustrate the intent of this policy will be subject to discipline.  An employee who is found to have acted in an improper or illegal manner, or, conversely, does not act in good faith under this policy, will also be subject to discipline up to and including termination.

If any member of the JTS staff has any questions or seeks additional information about this policy, please contact Mr. Oppenheimer at 212-678-8804 or maoppenheimer@jtsa.edu.

October, 2013