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Milwaukee Jewish Federation Whistleblower Protection Policy

I. Background and Purpose of Policy.  The Milwaukee Jewish Federation (MJF)  requires all employees to observe the highest standard of business and personal  ethics in the conduct of their duties and responsibilities. As representatives of the  Federation, employees must practice honesty and integrity in fulfilling  responsibilities and comply with all applicable laws and regulations. 

The purpose of this Whistleblower Protection Policy is to establish procedures that  ensure MJF’s board members, officers, employees and other key individuals can  “blow the whistle” by reporting good faith suspicions of illegal, unethical or other  inappropriate activity without fear of retaliation.

II.  Definitions.  The following words, phrases or terms used in the Whistleblower  Protection Policy shall have the following meanings:

A. “Complaint” shall mean any report regarding questionable accounting or auditing  matters, conflicts of interest, falsification of contracts, record or reports or  misconduct.

B. “Designated Person” shall mean the Treasurer or such other person or outside  entity designated by the Treasurer to receive Complaints.  The Designated Person  will be identified to board members, officers, employees and other key individuals  on an annual basis.

C. “Fact Finder” shall mean the person(s) or outside entity appointed by the  Treasurer to investigate the Complaint; and

D. “Fact Finding Report” shall mean the written report issued by the Fact Finder  containing a summary of the facts learned in the Fact Finder’s investigation and the  Fact Finder’s recommendations.

III. Prohibited Actions. 

 A. Accounting and Auditing Matters:

  1. Fraud or deliberate error in the preparation, evaluation, review or audit   of any financial statement of the Federation;
  2. Fraud or deliberate error in the recording and maintaining of financial records of  the Federation;
  3. The misapplication of generally accepted accounting principles; 
  4. Deficiencies in or noncompliance with the Federation’s internal accounting  controls;
  5. The misrepresentation of a fact or the making of a false statement to or by a  senior officer or accountant regarding a matter contained in the financial records,  financial reports or audits of the Federation;
  6. Deviation from full and fair reporting of the Federation’s financial condition;
  7. A violation of any state or federal statute, rule or regulation.

B. Conflicts of Interest: A situation in which an employee has a private or personal  interest sufficient to appear to influence the objective exercise of his/her official  duties. An example is having one’s relative work in a company in which the  individual controls MJF's business and this was not disclosed to and approved in  advance by the Federation.  Click here for further information on the Federation’s Conflict of Interest Policy.

C. Falsification of Contracts, Reports or Records: This consists of altering,  fabricating, falsifying or forging all or any part of a document, contract or record for  the purpose of gaining an advantage or misrepresenting the value of the document,  contract or records.

D. Misconduct: Any intentional wrongdoing on the part of a MJF employee that is a  deliberate violation of law or fiscal policy.