General: Bet Torah Synagogue believes that personally identifying information, such as your name, postal and e-mail address or telephone number, is private and confidential. You can have general access to our site without providing any personally identifying information. Bet Torah Synagogue collects personally identifying information only when you voluntarily submit it, such as when you e-mail comments, request information, sign up for a discussion group, or register for an event.
Release of Information to Third Parties: Bet Torah Synagogue does not release your personally identifying information to third parties unless you have given us permission to do so or unless such release is required to comply with the law or to protect the rights or safety of Bet Torah Synagogue or our Website users. Information that is collected will not be sold, shared, or rented to any outside company or organization. Information that is collected will be used solely for the purpose for which it is given.
Your Email and IP Address: We use your e-mail address and IP address to help diagnose problems with our server, and to administer our Web site. Your IP address provides information about how you and others navigate through and use our site. Your IP address may also be used to gather broad demographic information. An IP address that is collected on our site becomes the property of Bet Torah Synagogue. Bet Torah Synagogue does not sell, market or distribute these addresses to any other organizations and will not use it for purposes other than indicated in this policy.
Internet and E-mail: Information submitted to us via our web site, or via e-mail passes as clear text and is unencrypted. Safeguards are put in place to assure safe delivery of the electronic messages sent via e-mail and through our web site, but there is no assurance that such messages will not be intercepted. To submit confidential information to our office, please utilize fax, U.S. registered mail, or a courier. If you send us information through electronic mail you agree that we may do the same in communicating with you.
Conflict of Interest Policy
1. Conflicts of Interest
Any transaction, agreement or arrangement in which a Director, Officer or Key Employee of Bet Torah, Inc. (” BT”) has a financial interest and in which BT is a participant (a “Conflict Transaction”) must first be approved by a committee (“the Committee”) consisting of the President, the Treasurer and the Legal Counsel (each of whom must have no interest in the Conflict Transaction) and determined by the Committee that the Conflict Transaction is fair, reasonable, and in the best interests of Bet Torah.
At any time that a Director, Officer, or Key Employee is engaged or intends to engage in a Conflict Transaction, the nature and extent of that interest shall be promptly disclosed in writing to the Committee. On an annual basis, all Directors, Officers, and Key Employees shall disclose in writing, to the best of his or her knowledge, any Conflict Transaction that the Director, Officer, or Key Employee, has or may have.
3. Review of Transactions
In determining whether to approve a Conflict Transaction, the Committee shall take into account the restrictions regarding Related Party Transactions under Section 715 of the New York Not-for-Profit Corporation Law and the restrictions on Excess Benefit Transactions under section 4958 of the Internal Revenue Code of 1986, as amended. This Policy is intended to supplement but not replace any applicable state and federal laws governing conflicts of interest applicable to nonprofit and charitable organizations.
4. Attempts to Influence.
Directors, Officers, and Key Employees shall not attempt to influence the Committee regarding any vote on a Conflict Transaction in which that Director, Officer, or Key Employee has an interest.
In determining whether to approve a Conflict Transaction, the Committee shall document in its meeting minutes the basis for the Committee’s approval of the Conflict Transaction, including the material facts regarding any comparable transactions and any alternative transactions.
For purposes of this Policy:
“Key Employee” is a person who is, or has within the last five years, been in a position to exercise substantial influence over the affairs of Bet Torah. This includes, but is not limited to Bet Torah’s Executive Director, the Principal of Bet Torah’s religious school, and the principal of Bet Torah‘s Nursery School.
As adopted and approved by the Bet Torah Board of Directors, October 19, 2014.
Whistleblower Policy of Bet Torah, Inc.
Bet Torah, Inc. (“BT”) expects its directors, officers, and employees (hereafter, “Protected Persons”) to observe high standards of business and personal ethics relating to their roles at BT in the conduct of their duties and responsibilities when fulfilling their responsibilities to comply with all applicable laws and regulations.
The objectives of this Whistleblower Policy are to encourage and enable Protected Persons, without fear of retaliation, to raise concerns regarding suspected unethical and/or illegal conduct or practices on a confidential and, if desired, anonymous basis, so that BT can address and correct inappropriate conduct and actions.
It is the responsibility of all Protected Persons to report in good faith actual or suspected activities which may be illegal or in violation of BT’s policies with respect to, without limitation, fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, and misuse of BT’s assets, as well as any violations or suspected violations (“Violation”) of high business and personal ethical standards.
No Protected Person who in good faith reports a Violation shall suffer adverse consequences because of such report. An employee who retaliates against someone who has reported a Violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within BT prior to seeking resolution outside the organization with any additional rights or causes of action, other than those provided by law.
Any Violation should be reported as soon as is practicable, either orally or in writing, to BT’s Legal Counsel who will be responsible for investigating and resolving all reported Violations and shall advise the President and the Executive Director, as appropriate, of all reported complaints and allegations of Violations and proposed resolution.
Acting in Good Faith
Anyone filing a complaint concerning a Violation must act in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of such standards. Any allegations that prove not to be substantiated and which prove to have been made other than in good faith will be viewed as a serious disciplinary offense.
The Legal Counsel will retain on a strictly confidential basis for a period of three years all records relating to any complaint and to the investigation and resolution thereof.
The Corporation shall distribute a copy of this Whistleblower Policy to all Protected Persons.
Adopted by the Board of Directors at its Meeting held on October 19, 2014