It is the policy of the World Jewish Congress (American Section) Inc. (“WJC American Section”) to conduct our operations according to the highest ethical standards and to maintain the complete confidence of our donors, volunteers, employees, and members of governing entities. Volunteers and employees must conduct their personal affairs and manage their business transactions in a manner that does not result in adverse criticism from the public or in any way damage the Foundation’s reputation as a responsible organization.
It is the policy of the WJC American Section to fully comply with the intent and spirit of all applicable laws and regulations. The WJC American Section expects its volunteers and employees to use good judgment, to apply the highest ethical standards and to refrain from any form of illegal, dishonest, or unethical behavior.
It is the responsibility of each employee to be familiar and comply with the WJC American Section’s Ethics Policies.
The WJC American Section is committed to the highest possible ethical standards and we encourage everyone associated with the WJC American Section to commit to acting in the best interest of the WJCF and its mission.
As stewards of the WJC American Section and World Jewish Congress missions, we must uphold the public trust and act in an ethical manner in all that we do in the name of the WJC American Section. These ethical values include integrity, openness, honesty, accountability, fairness, respect and responsibility. These values are the basis of our Code of Conduct and commitment to act in a manner befitting the WJC American Section and its mission.
The WJC American Section relies on the public for funding and volunteer support, which is critical to the success of our mission. The public trusts us to carry out our stated mission and to act in the best interest of the WJC American Section.
Therefore, it is critical that we operate in a manner that is of the highest standards in all aspects, including governance, fundraising, mission operations, legal matters and human resources.
The WJC American Section is committed to:
- Acting responsibly and with integrity;
- Following the letter as well as the spirit of the law;
- Promoting financial accountability, transparency, and best governance practices;
- Respecting the diversity of those who support our mission through donations of their time, talent and money;
- Being responsible stewards of the WJC American Section, its mission, reputation, and resources;
- Being open and honest in all of our dealings with both internal and external audiences.
This Code of Conduct applies to all staff, volunteers and members of governing entities.
Accountability and Responsibility
All staff, members of governing entities and volunteers will:
- Be open and honest with colleagues, volunteers, donors, and all others involved in the WJC American Section and World Jewish Congress;
- Abide by the by-laws and policies of the WJC American Section;
- Take responsibility for their actions, and care in their dealings as representatives of the WJC American Section;
- Exercise best governance and accounting practices and procedures;
- Use the resources of the WJC American Section in a responsible and wise manner;
- Promote financial transparency while working to fulfill the mission of the WJC American Section.
All who serve in a position of authority over the WJC American Section will:
- Place the WJC American Section above other interests, financial or otherwise;
- Act in the best interest of the WJC American Section;
- Disclose any actual or perceived conflict of interest.
All members of our staff, governing entities and all volunteers will:
- Act in a responsible, ethical manner that promotes openness, fairness and integrity;
- Treat people with dignity and respect;
- Work together to achieve our mission to the best of our ability.
The WJC American Section is an equal opportunity employer and does not discriminate on the basis of race, color, religion, gender, or national origin. We value the
diversity of all people.
As a tax-exempt charitable organization, the WJC American Section has a special obligation to uphold the public trust. The affairs of the WJC American Section must be conducted in a manner that avoids impermissible private benefit, or the appearance of such private benefit. This obligation requires that any individual who has authority to make decisions on behalf of the WJC American Section, such as a director, officer, committee member or staff member, take steps to inform the WJC American Section Governing Board (“the Board”) of any personal interest he or she might have in a transaction or contract between the WJC American Section and a third party.
Duty of Loyalty and Intermediate Sanctions
Under the New York Not-For-Profit Corporation Law, directors and officers have a duty of loyalty to the WJC American Section obligating them to make decisions for the benefit of the WJC American Section with undivided commitment to the WJC American Section and without regard to personal interests. Furthermore as a public charity, the WJC American Section is subject to the "intermediate sanctions" provisions of the Internal Revenue Code. Intermediate sanctions impose penalty taxes on any person with substantial influence over the affairs of the WJC American Section who engages in an "excess benefit transaction" with the WJC American Section. Directors, officers, committee members and staff therefore may not use their positions within the WJC American Section to unfairly further their own financial interests or otherwise derive personal advantage.
While the duty of loyalty and intermediate sanctions do not preclude the WJC American Section from entering into contracts and transactions with its directors, officers, committee members and staff, the Board should be informed of any potential conflict of interest and authorize such transactions only after determining that they are both reasonable and in the best interests of the WJC American Section.
Conflict of Interest
A conflict of interest will arise whenever the WJC American Section considers entering into a contract or transaction (including a compensation arrangement) with any individual or entity that has a substantial influence over the affairs of the WJC American Section or has authority to make decisions on its behalf. Such "interested persons" include, but are not limited to, the following:
(i) Directors and officers of the WJC American Section;
(ii) Members of a committee of the Board;
(iii) Staff members responsible for the day-to-day management and operation of the WJC American Section;
(iv) A directors and officers of the World Jewish Congress;
(v) A substantial contributor to the WJC American Section;
(vi) A family member of any director, officer, committee member, employee, founder or substantial contributor;
(vii) an entity of which any director, officer, committee member, employee, substantial contributor or a family member of any such individual is a director, trustee, officer, committee member or staff member; and
(viii) an entity in which directors, officers, committee members, substantial contributors and family members of any such individuals have a substantial financial interest through either ownership or managerial control.
Whenever any director, officer, committee member or staff member of the WJC American Section becomes aware that the WJC American Section is considering a transaction that potentially creates a conflict of interest, he or she is obligated to notify the Board and to disclose all material facts relating to his or her interest in the transaction. The Board will determine whether an actual conflict of interest exists and take action that the Board deems appropriate. The interested person may not be present when the Board makes its determination other than to answer questions. If no conflict of interest is found to exist, the minutes of the meeting must record the basis of the Board's determination.
Withdrawal and Abstention
If the Board determines that a transaction would create a conflict of interest, the transaction must be approved in advance by only those Board members who do not have a conflict with respect to the transaction. Any interested person therefore must recuse him- or herself from consideration of the transaction. He or she may not vote on the transaction or be present when the vote is taken. He or she furthermore may not be present during any discussion of the transaction other than to answer questions. Interested persons, however, may be counted for the purpose of determining whether a quorum exists at the meeting even though they are temporarily absent while the transaction is considered.
In determining whether the transaction or arrangement is in the WJC American Section’s best interests, the Board will review available information regarding the cost or benefit of comparable transactions or arrangements, if any, and may investigate whether the WJC American Section should and is able to obtain with reasonable efforts a more advantageous transaction or arrangement that would not give rise to a conflict of interest. The Board may appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
The minutes of any meeting at which a conflict of interest transaction is considered must reflect that the interested person made adequate disclosures, withdrew from consideration of the transaction and abstained from voting. The minutes must detail the terms of the transaction, the date the transaction was approved, the Board members present during the debate and who voted on the transaction, any data the Board relied upon in determining that the transaction is reasonable and in the best interests of the WJC American Section, how such comparability data was obtained, the disclosures made by the interested person, and whether the interested person otherwise participated in any discussions or proceedings (i.e., to answer questions). As with all minutes, the minutes documenting a conflict of interest transaction must be reviewed and approved by the Board at its next meeting.
Relationships with Grant Applicants
Directors are required to disclose any relationship between themselves and any grant applicant under consideration and/or any special interest they may have in an applicant or the particular project proposed. Such directors may participate in discussions of the application (unless, under the particular circumstances, the Board decides otherwise) but must abstain from voting on the applicant. There is no prejudice against the applicant nor is an applicant disqualified due to any such disclosure.
Each director, officer, committee member and staff member must sign a statement which affirms that such person: (a) has received a copy of this Conflict of Interest Policy, (b) has read and understands this Policy, and (c) has agreed to comply with this Policy.
Violations of the Conflict of Interest and Disclosure Policy
If the Board or a committee has reasonable cause to believe that an interested person has failed to disclose an actual or possible conflict of interest, it will inform the interested person of the basis for such belief and afford him or her an opportunity to explain the alleged failure to disclose. If you wish to submit the potential conflict confidentially and anonymously, you may contact our third-party provider EthicsPoint online at www.ethicspoint.com or by calling 866-870-0961. These rmatters are treated with priority. If, after hearing the response and making such further investigation as may be warranted in the circumstances, the Board determines that the interested person has in fact failed to disclose an actual or possible conflict of interest, it will take appropriate action which may include recommendation to the Board for removal from the Board or termination of employment, as well as reconsideration of whether the transaction or arrangement was in the best interests of and fair and reasonable to the WJC American Section at the time it was undertaken. If it is determined that the transaction was not fair and reasonable to the WJC American Section, the WJC American Section, in its discretion, may void the contract and/or require the interested person to restore the WJC American Section to the financial position it would have been in if such person had been dealing under the highest fiduciary standard. Where the latter remedy is employed, the interested person will be required to make payments of cash or property to the WJC American Section in amounts equal to the value of the excess benefit he or she received plus interest. Any interested person who violates this Policy also may be liable for taxes imposed under the federal intermediate sanctions regulations.
Our role, as stewards of our mission, demands that we – all members of governing entities, staff and volunteers – uphold the public trust and act in an ethical manner in all of our commitments to the WJC American Section. These ethical values include integrity, openness, honesty, accountability, fairness, respect and responsibility. The WJC American Section is committed to the highest possible ethical standards and we encourage everyone associated with the WJC American Section to commit to acting in the best interest of the WJC American Section.
In order to facilitate open and honest communication, the WJC American Section has established a Code of Conduct for our employees, its Board and volunteers. We are committed to maintaining a positive, ethical work environment for everyone of the WJC American Section.
Should you suspect fraud, abuse or misuse of the WJC American Section’s resources or assets; encounter dishonest actions or deeds; suspect conflict of interest; experience or are aware of harassment of any kind; or any other behavior that violates the WJC American Section’s Codes, or local laws and regulations, you have a responsibility to report the violation or suspected violation to the appropriate person within the WJC American Section.
We expect any report of a violation will be made in good faith, and is a real and legitimate concern that you believe should be addressed.
Protection Under Policy
The WJC American Section will not knowingly, with the intent to retaliate, take any action harmful to any staff member or trustee, including interference with lawful employment or livelihood, for:
- reporting a complaint in good faith pursuant to this policy or to law enforcement officers governmental agencies or bodies, or persons with supervisory authority over the complainant;
- providing in good faith information regarding a complaint to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant, or otherwise assisting in any investigation conducted by the WJC American Section; or
- otherwise participating or assisting in a proceeding filed or about to be filed.
An individual who deliberately or maliciously provides false information may be subject to disciplinary action, up to and including termination of employment.
We invite anyone involved in any aspect of the WJC American Section to report violations or suspected violations. All violations or suspected violations should be reported to your immediate supervisor or the Executive Director or, if necessary, to the General Counsel or Director of Finance and Administration of the WJC LLC.
All credible allegations will be followed up promptly by the Executive Director, the Board or a committee authorized by the board to follow up on the Complaint with further investigation conducted, if needed, to resolve disputed facts.
In conducting its investigations and in reporting complaints, the WJC American Section will strive to keep as confidential as possible the identity of any complainant or any individual who provides information during an investigation.
If you wish to remain anonymous when making your report, we have secured the services of EthicsPoint, a third-party provider of confidential, anonymous reporting service to accept these reports.
When you contact any one of the above, you can expect that:
- You will be treated with dignity and respect;
- Your communication will be protected to the greatest extent possible;
- Your concerns will be seriously addressed and, if not resolved at the time you call, you will be informed of the outcome;
- You need not identify yourself.
All reports involving a violation are treated seriously and will be fully investigated to determine the facts and resolution appropriate under the circumstances.
Please remember that there is never a penalty for bringing your concerns forward. People in a position of authority cannot stop you; if they try, they are subject to disciplinary action up to and including dismissal.