Whistleblowing policy  

The Jewish General Hospital Foundation (the “Foundation”) is a registered Canadian charity that is committed to high standards of ethical, moral and legal business conduct. The Foundation is dedicated to acting in good faith with those directors, officers, committee members and employees who raise concerns regarding unlawful or unethical behaviour in connection with the financial affairs of the Foundation. 

The purpose of this Policy is to provide directors, officers, committee members, employees, Foundation donors and volunteers with an avenue for raising good faith concerns regarding unlawful or unethical behaviour in connection with the financial, legal and regulatory affairs of the Foundation and to reassure such persons that they will be protected from reprisal, retaliation or victimization as a consequence of reporting the alleged wrongdoing.

This Policy applies to the Foundation’s directors, officers, committee members and employees. 

The Foundation intends this Policy to be used for serious issues. Examples of such issues include, but are not limited to, the following: 

The Foundation will not retaliate against directors, officers, committee members or employees who in good faith raise a concern in accordance with this Policy. No action will be taken against that individual in the case where an allegation is not confirmed by subsequent investigation. In raising a concern, the individual should exercise due care to ensure the accuracy of the information. If, however, an individual raises a concern in bad faith or knowingly provides false or materially inaccurate information, disciplinary action may be taken against that individual. 

Concerns about a perceived wrongdoing concerning the financial affairs of the Foundation should immediately be raised with either the Vice-President, Finance and Administration, the President and CEO or the Chair of the Foundation’s Audit Committee. Concerns may be raised directly with the Chair of the Audit Committee by leaving a detailed message on the dedicated Whistleblower Hotline: 514‐340‐8222, extension 28866 to which only the Chair of the Audit Committee has access. In addition, an online form shall be made available to raise a concern. 

Although a complainant is not expected to prove the truth of a concern raised, they should be able to demonstrate that they have made a report in good faith. 

The Vice-President, Finance and Administration, the President and CEO or the Chair of the Audit Committee, as the case may be, or someone appointed by them, will make initial inquiries in consultation with legal or accounting counsel, if necessary, to determine whether or not further investigation is necessary or appropriate. In all cases, the Chair of the Audit Committee shall be informed of any concern raised in accordance with this Policy. 

The Chair of the Audit Committee or another officer, or a senior member of the Foundation professional team who is not named in the allegation and who has been appointed by the Chair of the Audit Committee to investigate the complaint, may seek further information from any officer, director, employee, contractor, volunteer or stakeholder of the Foundation, and shall take all reasonable precautions to protect the identity of the complainant to the extent possible while doing so. The actions taken by the Foundation with respect to a particular allegation will depend on the nature of the concern raised. 

Each case is unique but the Foundation will handle any concern raised pursuant to this Policy respectfully and with discretion. Each case will be reported to the Audit Committee at the Committee’s next meeting. 

The Foundation will make every effort to treat the identity of a complainant or the subject of the concern raised with an appropriate regard for confidentiality, with the understanding that the details may need to be shared with others in order to investigate such concern properly. 

Thorough investigation often depends on an ability to gather additional information. The Foundation encourages complainants to put their names to concerns raised. The Foundation will explore anonymous concerns to the extent possible but will weigh the prudence of continuing an investigation against the likelihood of confirming the alleged facts or circumstances from attributable sources. 

Once the investigation has been completed, the Audit Committee shall recommend action or no further action, as the case may be, and the Chair of the Audit Committee shall report the event and the recommendation of the Audit Committee to the Board of Directors of the Foundation. 

Records of all concerns raised under this Policy shall be maintained by the Secretary of the Audit Committee. 

Annual training and reminders concerning this Policy shall be conducted. This Policy’s existence and related procedures shall be prominently displayed on all relevant Foundation platforms.  

Last updated: November 2024