A. Authority of Audit Committee--All reported concerns will be forwarded to the Chair of the Trustee Audit Committee in accordance with the procedures set forth herein. The Audit Committee shall be responsible for investigating, and making appropriate recommendations to the Board of Trustees, with respect to reported concerns, as deemed appropriate.
B. No Retaliation--This Whistleblower Policy is intended to encourage and enable Trustees, volunteers, staff and faculty members to raise concerns for investigation and appropriate action. With this goal in mind, no Trustee, volunteer, staff or faculty member who, in good faith, reports a concern shall be subject to retaliation or, in the case of a staff or faculty member, adverse employment consequences. Moreover, retaliation against someone who has reported a concern in good faith will be viewed as a serious offense and any disciplinary action will follow policies and procedures that govern the individual(s) involved.
C. Reporting Concerns
1. Employees and Volunteers--Volunteers (other than Trustee Volunteers), faculty or staff members should first discuss their concern with their immediate supervisor. If, after speaking with his or her supervisor, the individual continues to have reasonable grounds to believe the concern is valid or has not been appropriately dealt with, the individual should report the concern to the Vice President for Finance and Administration. If the individual is uncomfortable speaking with his or her supervisor, or the supervisor is a subject of the concern, the individual should report his or her concern directly to the Vice President for Finance and Administration. If the concern was reported verbally to the Vice President for Finance and Administration, the reporting individual will be asked to reduce the concern to writing. The Vice President for Finance and Administration is required to promptly submit the written report to the Chair of the Audit Committee, who has specific and exclusive responsibility to investigate all concerns. If the Vice President for Finance and Administration, for any reason, does not promptly forward the concern to the Audit Committee, or the reporting individual believes the Vice President may be involved in the concern or is otherwise not affording the concern appropriate attention, the reporting individual should directly report the concern to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained through the President’s Office. Concerns may also be submitted anonymously, either to the Vice President for Finance and Administration or the Chair of the Audit Committee.
2. Trustees--Trustees should submit concerns in writing directly to the Chair of the Audit Committee. Contact information for the Chair of the Audit Committee may be obtained from the President’s Office.
3. Handling of Reported Violations--The Audit Committee shall address all reported concerns. The Chair of the Audit Committee shall immediately notify the President and the Vice President for Finance and Administration of any such report. The Chair of the Audit Committee will notify the sender and acknowledge
receipt of the concern within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted concerns.
All reports will be promptly investigated by the Audit Committee, and appropriate corrective action will be recommended, if warranted by the investigation. In addition, action taken
will include a conclusion and/or follow-up with the complainant for complete closure of the concern. The Audit Committee has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
4. Acting in Good Faith--Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates an improper accounting or auditing practice, or a violation of the principles outlined under Background (above). The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious offense and any resultant disciplinary action will follow policies and procedures that govern the individual(s) involved.
5. Confidentiality--Reports of concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Disclosure of reports of concerns to individuals not involved in the investigation will be viewed as a serious offense and any resultant disciplinary action will follow policies and procedures that govern the individual(s) involved.