The Young Men's Christian Association Retirement Fund
Whistleblower Policy

Procedures
Action on Complaints
Protection Under the Policy
Scope of the Policy
Confidentiality
Policy Amendment

Each employee and Trustee of the YMCA Retirement Fund (Fund) has an obligation to immediately report any illegal or unethical conduct in connection with the Fund’s resources or financial operations.

Procedures

1. Any employee or Trustee of the Fund may submit a complaint, which may be made on an anonymous basis. Complaints may be made by telephoning or writing to the Audit Committee Chairman or the Fund’s General Counsel.
2. The Audit Committee Chairman or other individuals as he directs will thoroughly investigate each complaint. The Audit Committee Chairman will bring the matter to the Audit Committee and will report any complaint that the Audit Committee determines to be credible and material to the Board of Trustees of the Fund.
3. The Audit Committee may enlist employees of the Fund and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints.
4. The General Counsel or outside legal counsel shall keep a written record of all complaints and provide monthly reports to the Audit Committee Chairman, as the Audit Committee Chairman shall direct. The Audit Committee will retain, as part of the records of the Audit Committee, any such complaints, as well as its investigations and resolutions of complaints, for a period of no less than seven years.

Action on Complaints

Following evaluation by the Audit Committee Chairman or his designees, and after notification to and review by the Audit Committee, the Fund will take appropriate action in response to any complaints, including disciplinary action (up to and including termination of employment) against any person who has engaged in unethical conduct or misconduct and, where appropriate, reporting such misconduct to the relevant civil or criminal authorities.

Protection Under the Policy

The Fund will not knowingly, with the intent to retaliate, take any action harmful to any employee or Trustee, including interference with lawful employment or livelihood, for:

• Reporting a complaint in good faith pursuant to this policy or to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant;
• Providing in good faith information regarding a complaint to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant, or otherwise assisting in any investigation conducted by the Fund; or
• Otherwise participating or assisting in a legal or administrative proceeding filed or about to be filed.

An individual who deliberately or maliciously provides false information, as determined by the Chairman of the Audit Committee, may be subject to disciplinary action, up to and including termination of employment.

Scope of the Policy

This Policy covers complaints made regarding the Fund’s resources or financial operations.

Set forth below are types of allegations that constitute whistleblower claims that fall within the scope of this Policy. This list is not intended to be all inclusive.

• Misappropriation of the Fund’s assets.
• The unethical recording and analysis of the business and financial transactions associated with generally accepted accounting principles (GAAP), such as misstatement of revenues/expenses, misstatement of assets, and wrongful transactions.
• Unauthorized and unlawful disclosure of Fund information, such as employee, participant, marketing and other databases.
• Falsification of records consisting 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 record.
• The act of stealing; specifically, the felonious taking and removing of personal property with intent to deprive the rightful owner of the property.

This Policy is in addition to, and separate from, the Fund’s policies on Conflict of Interest and on Equal Employment Opportunity, including the Policy Against Harassment, in the Fund’s Personnel Policy and Procedures. Mechanisms for resolving such issues are addressed in separate procedures.

Confidentiality

In conducting its investigations and in reporting complaints, the Fund will strive to keep as confidential as possible the identity of any complainant or any individual who provides information during an investigation.

Policy Amendment

Amendments to this Policy may be made by the Board of Trustees or the Audit Committee.