CORPORATE GOVERNANCE REPORTING POLICY

The New York Convention Center Operating Corporation (the “Javits Center” or “Center”) is committed to high standards of ethical, moral and legal business conduct. In line with this commitment, and the Center’s commitment to open communication, this Corporate Governance Reporting Policy provides an avenue for employees, officers, directors and other third parties to communicate their questions and concerns about suspected or known instances of wrongdoing, and reassurance that they will be protected from retaliation for filing a report.

 

“Wrongdoing”, includes but is not limited to any alleged:

    • Corruption
    • Fraud
    • Criminal Activity
    • Conflict of interest
    • Accounting, Internal Control or Audit Irregularities
    • Intentional Reporting of False or Misleading Information
    • Any violation of the Javits Center’s Code of Conduct
    • Any violation of any applicable law or regulation.

Wrongdoing, for the purposes of this policy, does not include conduct covered by the Javits Center’s anti-discrimination and anti-harassment policy which should be reported to the Center’s EEO Compliance Manager at 212-216-2197, or conduct covered by the Javits Center Workplace Violence Prevention Program which should be reported to the VP of Security & Safety Solutions at 212-216-2379.

Any person having information about possible wrongdoing occurring at or affecting the Javits Center is encouraged to report those concerns to the Javits Center (“Report”). The Javits Center has an Ethics Hotline administered by an independent third party where a report can be made in either English (844-450-0005) or Spanish (800-216-1288). Reports may also be filed through the independent third party via the internet at www.lighthouse-services.com/javitscenter or emailed to reports@lighthouse-services.com. The Ethics Hotline is accessible 24 hours a day and provides a secure way for individuals to report concerns.

 

In addition to the Ethics Hotline, Reports may be filed with:

    • Director of Internal Control and Compliance - Allison Richardson, in person or by phone (212-216-2387)
    • Office of the Inspector General, by phone (800-367-4448) or through its website (www.ig.state.ny.us)
    • The Authorities Budget Office, by phone (800-560-1770)

 

Reports may be filed anonymously. However, we strongly encourage individuals filing Reports to provide their name and contact information, to better enable the Center to properly investigate allegations contained in any Report. It is also important to include as much factual detail as possible, including names of individuals involved, dates and places of relevant events, as well as sources of potential supporting materials such as e-mails, invoices or other documentation. By providing sufficient detail the Center has a better ability to fully and accurately investigate Reports.

 

Employees should be aware that under the Public Authorities Accountability Act of 2005, the knowing failure by an employee to report corruption, fraud, criminal activity, conflicts of interest and abuse of office may result in dismissal or other appropriate sanction.

 

Reports filed with the Ethics Hotline or the Director of Internal Control and Compliance will be logged, given a unique reference number and will be promptly investigated. Individuals filing Reports with the Ethics Hotline or the Director of Internal Control and Compliance will be provided the unique reference number and may follow up for a status of their Report.

It is critical for individuals to know that they will not suffer any adverse consequences for making a Report pursuant to this the policy or cooperating in any investigation in connection with such Report. Consequently, no Javits Center representative shall retaliate against any individual for filing a good faith Report or cooperating in an investigation, whether through threat, coercion, or abuse of authority; and, no Javits Representative shall interfere with the right of any individual by any improper means aimed at deterring disclosure of potential wrongdoing. Any attempts at retaliation or interference are strictly prohibited. Any act of alleged retaliation should be reported immediately to the General Counsel at 212-216-2120.

If requested to do so, the Javits Center will endeavor to protect the identity of any individual making a Report or cooperating in any investigation. However, under certain circumstances the Center may be required to disclose a Reporter’s or cooperating witness’s identity.

Any individual filing a Report under this policy is expected to do so upon a good faith basis. Their suspicions or concerns need not, in fact, be true, but must have a reasonable basis. Any individual who knowingly files a Report which contains false allegations shall be subject to disciplinary action, up to and including termination.

This Corporate Governance Reporting Policy is not intended to limit, diminish or impair any other rights or remedies that an individual may have under the law with respect to disclosing potential wrongdoing free from retaliation or adverse personnel action.

    • Specifically, this Corporate Governance Reporting Policy does not limit any rights or remedies that an individual may have under the laws of the State of New York, including but not limited to Civil Service Law § 75-b, Labor Law § 740, State Finance Law § 191 (commonly known as the “False Claims Act”), and Executive Law § 55(1).
    • With respect to any rights or remedies that an individual may have pursuant to Civil Service Law § 75-b or Labor Law § 740, any employee who wishes to preserve such rights shall prior to disclosing information to a government body outside the Javits Center, have made a good faith effort to provide the Javits Center the information to be disclosed and shall provide the Javits Center or its designee a reasonable time to take appropriate action unless there is imminent and serious danger to public health or safety. (See Civil Service Law § 75-b[2][b]; Labor Law § 740[3]).

If you have any questions regarding this policy, please contact the Director of Internal Control and Compliance - Allison Richardson - at 212-216-2387. In addition, you may contact the Authorities Budget Office at with questions at 800-560-1770, for an explanation of your rights, options and responsibilities under applicable state and federal laws.

Date: 1/6/17