The Jewish Agency Whistleblower Policy
[Updated version, approved by the Board of Governors July 2022]
1. STATEMENT OF POLICY
JAFI is committed to taking action to prevent committing offenses, unethical conduct and improper administration of JAFI. JAFI urges to come forward with any such information, without regard to the identity of the involved parties.
This policy applies to all: (i) members of the Executive (ii) members of the BOG; (iii) honorary members; (iv) associate members of the Executive; (v) associate members of the BOG; (vi) committee members; (vii) observers and regular invitees to the Executive and BOG meetings; (viii) employees of JAFI or others employed by it (hereinafter jointly: “Member” or “Members”, as the case may be).
3. PROHIBITED ACTIONS
Execution of any of the acts detailed in the following paragraphs 3.1 – 3.4 below will be considered as a cause for immediate disciplinary action. For the purpose of this policy the term “disciplinary action” includes but is not limited to, termination of office or employment. JAFI may also consider, in addition to the above, and according to circumstances whether to file a complaint with the police regarding the reported act.
3.1. Intentionally destroying, altering, mutilating, concealing, covering up, falsifying or making a false entry in any records that may be connected to a matter relating to JAFI contrary to all laws, to the basic documents of JAFI and its procedures (hereinafter jointly: “JAFI Procedures”).
3.2. Attempt to perform any of the actions enumerated in paragraph 3.1. above, inter alia with intent to impair, influence or imped any official proceeding, that JAFI is involved in.
3.3. Fraudulently influencing, coercing, manipulating, or misleading JAFI Comptroller and/or any independent public accountant engaged in the performance of a review, or of an audit of the financial statements of JAFI, for the purpose of distorting such review or financial statements misleading.
3.4. Discharging, demoting, suspending, threatening, harassing, discriminating or retaliating or otherwise taking any action harmful in any manner against any Member, because of any lawful act by that Member who:
a) Provides what he reasonably believes to be truthful information to, or assists in any investigation by, any Government Ministry or statutory authority, or JAFI or JAFI Comptroller;
b) Files or assists in any action related to the filing of a complaint alleging a violation of the law or a violation of JAFI procedures; or
c) Provides truthful information to the law enforcement authorities for the purpose of law enforcement relevant to the offense that is suspected of being committed.
4.1. This Policy prohibits any and all forms of retaliation against any Member who: (a) in good faith provides any information or reports any corrupt conduct and/or activity; or (b) makes a good faith and appropriate complaint regarding violation of this Policy; (c) assists in any investigation or the examination of an alleged violation of this Policy.
4.2. The provisions of paragraph 4.1. above shall not apply if the Member has made an unjustified claim not in good faith, in circumstances where the Member knew or should have known that such claim was unjustified. Execution of such acts will be considered a cause for immediate disciplinary action, including, but not limited to, termination of office or termination of employment.
4.3. The provisions of this Section are subject to the Law for the Protection of Employees (Exposure of Offenses, of Unethical Conduct and of Improper Administration) Law, 5757-1997 which applies to JAFI, regarding the protection of employees who report a possible violation in accordance with this Policy.
5. FILING COMPLAINTS AND REPORTING ON CONCERNS
JAFI Comptroller will receive complaints or information regarding suspected offenses, unethical conduct and improper administration of JAFI.
Filing complaints or reporting on concerns will be by calling the toll-free number at: 1800-300-221 or the number: 972-2-6204510 or via e-mail: firstname.lastname@example.org. The communication can be anonymous or identified, at the choice of the complaint.
It is the responsibility of the Secretary General to distribute this policy document to the members listed in section 2(i)-(vi) above. It is the responsibility of the Deputy Director General for Human Resources and Administration to distribute this policy document among the employees of the Jewish Agency or others employed by it.
JAFI will treat all communications regarding the implementation of this Policy in a confidential manner, except to the extent necessary (1) to conduct a complete and fair investigation, or (2) for review of JAFI operations by its authorized bodies.