Whistleblower Protection Policy

 Purpose

The UNFCU Foundation (“Foundation”) is committed to high standards of ethical, moral and legal business conduct. In line with this commitment and Foundation’s commitment to open communication, this policy aims to provide an avenue for current and former employees, volunteers, and independent contractors to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing.

This Whistleblower Policy is intended to cover protections for you if you raise concerns
regarding Foundation, such as concerns regarding:

• incorrect financial reporting;
• unlawful activity;
• activities that are not in line with Foundation policy, including but not limited to the conflicts of interest policy; or
• activities which otherwise amount to improper conduct.

Statement of Policy

No officer, director, employee, volunteer or agent of Foundation shall take any harmful action
with the intent to retaliate against any person, including interference with employment or
livelihood, for providing to a law enforcement officer any truthful information relating to the
commission or possible commission of any offense. Nor will any officer, director, employee,
volunteer or agent take any harmful action with intent to retaliate against any employee or
member of Foundation for reporting to an appropriate senior management or elected official of
Foundation the suspected misuse, misallocation or theft of any Foundation resources.

Safeguards

Harassment or Victimization – Harassment or victimization for reporting concerns under this
policy will not be tolerated.

Confidentiality – Every effort will be made to treat the complainant’s identity with appropriate
regard for confidentiality.

Anonymous Allegations – This policy encourages employees to put their names to allegations
because appropriate follow-up questions and investigation may not be possible unless the source
of the information is identified. Concerns expressed anonymously will be explored appropriately,
but consideration will be given to:

• The seriousness of the issue raised;
• The credibility of the concern; and
• The likelihood of confirming the allegation from attributable sources.

Protected Allegations – All allegations based on a reasonable belief that there is a violation are
protected under this policy. Allegations made in bad faith without any reasonable basis for the
claims may result in disciplinary action.

Procedure

Process for Raising a Concern:

Reporting – The whistleblowing procedure is intended to be used for serious and sensitive issues.
Such concerns, including those relating to financial reporting or unethical or illegal conduct, may
be reported directly to:

• By Mail: 24-01 44th Road, Long Island City, New York 11101
• By Email:  contact@unfcufoundation.org

Timing – The earlier a concern is expressed, the easier it is to take action.

Evidence -Although the complainant is not expected to prove the truth of an allegation, he or she
should be able to demonstrate to the person contacted that the report is being made in good faith.

Conflicts – A person who is the subject of an allegation shall not be present at or participate in
any decision making related to such allegations. This shall not prohibit the person who is the
subject of the complaint to present information as background or answer questions as part of the
assessment of the allegations.

How the Report of Concern Will Be Handled:

The action taken by Foundation in response to a report of concern under this policy will depend
on the nature of the concern. The officers and directors of the Foundation shall receive
information on each credible report of concern and follow-up information on actions taken.

Initial Inquiries – Initial inquiries will be made to determine whether an investigation is
appropriate, and the form that it should take. Some concerns may be resolved without the need
for investigation.

Further Information -The amount of contact between the complainant and the person or persons
investigating the concern will depend on the nature of the issue and the clarity of information
provided. Further information may be sought from or provided to the person reporting the
concern.

The Foundation reserves the right to modify or amend this policy at any time as it may deem necessary.