In compliance with Section 715-B of the Not-for-Profit Corporation Law and Section 740 of the Labor Law, these procedures are adopted by the Board of The Legal Aid Society, after consideration by the Audit Committee of the Board, to provide a mechanism for communicating to the Society’s General Counsel and to the Audit Committee complaints and other information about any action or suspected action that is illegal, fraudulent or in violation of any adopted policy of the corporation. These policies include but are not limited to those regarding internal controls, bidding, purchasing and contracting practices, expense reimbursement policies, use of Society property, including communication systems, conflicts of interest, auditing and accounting issues or other financial matters or legal requirements.

1. As the nation’s oldest, largest and most-honored organization devoted to providing legal services to the poor, The Legal Aid Society can be proud of the high standards of integrity and ethics which all of our directors and employees (including, without limitation, officers) adhere to, day in and day out, in the carrying out of our mission. The Society from time to time adopts specific policies in order to give its directors and employees (including, without limitation, officers) specific guidance as to how we expect the Society’s obligations to its clients and to its own institutional well-being should be met. In this regard, The Legal Aid Society expects that every director and employee (including, without limitation, each officer) will obey the law, act ethically and abide by Society policies.

2. If you know of conduct that you believe is illegal, fraudulent, or in violation of any adopted policy of the Society, you should immediately communicate this information to the Society. This can be done several ways. You can:

a. communicate directly to the Society’s General Counsel,
b. send a letter to the General Counsel without identifying yourself, which lets you raise your concern anonymously, or
c. in circumstances where you feel that either of the above methods would not be fully effective, communicate directly with the Chair of the Audit Committee of the Board.

3. Any communication made pursuant to this policy will be treated as strictly confidential.

4. The Society will promptly review your report of unlawful or unethical conduct.

5. You should feel free to communicate your concerns on an anonymous basis. You should be aware, however, that anonymity could become an obstacle to full review and resolution of a concern by the Society.

6. The Society will not take any retaliatory action against any director, employee (including, without limitation, an officer), former employee (including, without limitation, a former officer), or independent contractor, whether or not within the scope of such person’s job duties, because such person does any of the following:

(A) discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice of the employer that the person reasonably or in good faith believes is in violation of law, rule, regulation or policy, or that the person reasonably or in good faith believes poses a substantial and specific danger to the public health or safety;

(B) provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into any such activity, policy or practice by such employer; or

(C) objects to, or refuses to participate in any such activity, policy or practice.

For the meaning of “retaliatory action,” see Section 740(1)(e) of the Labor Law. The protection against retaliatory action pertaining to disclosure to a public body shall not apply to such person who makes such disclosure to a public body unless such person has made a good faith effort to notify the Society by bringing the activity, policy or practice to the attention of a supervisor of the Society and has afforded the Society a reasonable opportunity to correct such activity, policy or practice. Such employer notification shall not be required, however, where:

i. there is an imminent and serious danger to the public health or safety;
ii. the person reasonably believes that reporting to the supervisor would result in a destruction of evidence or other concealment of the activity, policy or practice;
iii. such activity, policy or practice could reasonably be expected to lead to endangering the welfare of a minor;
iv. the person reasonably believes that reporting to the supervisor would result in physical harm to the person or any other person; or
v. the person reasonably believes that the supervisor is already aware of the activity, policy or practice and will not correct such activity, policy or practice.

7. The General Counsel is designated as the person responsible for administering the Whistleblower Policy. The General Counsel will investigate or arrange for the investigation of any report made pursuant to this policy, which may include engaging an independent person or entity to investigate the report, and will make timely reports to the Audit Committee regarding all such reports and investigations.

8. The person who is the subject of a whistleblower complaint will not be present at or participate in board or committee deliberations or vote on the matter relating to such complaint, provided that nothing in this subparagraph shall prohibit the board or committee from requesting that the person who is subject to the complaint present information as background or answer questions at a committee or board meeting prior to the commencement of deliberations or voting relating thereto.

9. A copy of this policy will be posted on the Society’s website and in easily accessible and well-lighted places customarily frequented by employees and applicants for employment.

10. The Society has adopted and promulgated a Policy and Procedure Against Discrimination and Harassment. Any individual who believes any provision of that Policy has been violated should follow the procedures set forth in that policy which requires that such conduct be reported to the Attorney or Administrator in charge of his or her office, the Attorney or Administrator in charge of his or her practice area or the Society’s Director of Human Resources or any manager in the Human Resources Department. The procedures set forth in the Discrimination and Harassment Policy are to be followed when you believe that any provision of the Discrimination and Harassment Policy has been violated.

Adopted by the Board of Directors on November 17, 2005
Amended by the Executive Committee of the Board of Directors on May 6, 2014
Amended by the Executive Committee of the Board of Directors on May 14, 2025