General Description
Policy Summary:
This Policy governs the use of the Whistleblower Hotline for the purpose of reporting acts considered to be potentially illegal, fraudulent, dishonest, abuse of authority/abusive behavior and/or of a similar nature. This policy also strictly prohibits retaliation against an employee or student of the University (referred to here as a "Whistleblower") who reports an activity that the Whistleblower reasonably believes to be illegal, fraudulent, dishonest or otherwise warranting reporting on the hotline.
Purpose:
The purpose of this policy is to promote transparency and accountability within the University by encouraging the reporting of misconduct while protecting whistleblowers from retaliation.
Scope:
This policy applies to faculty, staff, students who are also employees, as well as third parties within the University’s control (such as contractors, volunteers, visitors, etc.).
Exceptions:
None.
Responsible Department:
- Risk Management
Policy Content
All members of the University community are responsible for reporting fraudulent, dishonest, or illegal conduct involving University employees or resources. The University's official reporting channel for such matters, the Campus Conduct Hotline, is provided and managed by the University’s insurance provider to ensure confidentiality. You can access the Campus Conduct Hotline’s confidential phone number (866-943-5787) or confidential website at www.lighthouse-services.com/CCH2562. A confidential code is provided to the person reporting the incident whereby the caller can track progress and resolution of the matter throughout the investigation process.
Reports submitted to the hotline are forwarded to the Office of the General Counsel and the University Risk Management Office. A copy is provided to the appropriate vice president for investigation and resolution. Management investigation progress, including any corrective action taken and final resolution of the matter, are reported by Risk Management Office to the hotline.
The General Counsel will determine, in consultation with appropriate administrative officials disinterested in the reported case, if the matter should be reported immediately to the Chair of the Audit Committee of the Board of Trustees. All matters reported on the hotline are included in a summary report form to the Audit Committee on an annual basis.
Reports submitted to the hotline are forwarded to the Office of the General Counsel and the University Risk Management Office. A copy is provided to the appropriate vice president for investigation and resolution. Management investigation progress, including any corrective action taken and final resolution of the matter, are reported by Risk Management Office to the hotline.
The General Counsel will determine, in consultation with appropriate administrative officials disinterested in the reported case, if the matter should be reported immediately to the Chair of the Audit Committee of the Board of Trustees. All matters reported on the hotline are included in a summary report form to the Audit Committee on an annual basis.
University employees may not retaliate against a Whistleblower with the intent or effect of adversely affecting the terms or conditions of employment or enrollment.
If the Whistleblower has made a confidential report, the University will exercise reasonable care to keep the Whistleblower's identity and the report confidential unless:
(1) The whistleblower agrees to the disclosure;
(2) disclosure is necessary to allow University or law enforcement officials to investigate or respond effectively to the report;
(3) disclosure is required by law; or
(4) the person(s) accused of violations by the Whistleblower are entitled to the information as a matter of institutional due process in disciplinary proceedings.
Whistleblowers who reasonably believe that a University employee or student has retaliated against them may file a written complaint with the General Counsel, with a copy to the Vice President of People, Culture, and Community. If retaliation is substantiated, the retaliating employee(s) are subject to appropriate disciplinary actions or remedies, up to and including dismissal. The prohibition against retaliation is not intended to prohibit managers or supervisors from exercising legitimate supervisory responsibilities in the usual scope of their duties.
If the Whistleblower has made a confidential report, the University will exercise reasonable care to keep the Whistleblower's identity and the report confidential unless:
(1) The whistleblower agrees to the disclosure;
(2) disclosure is necessary to allow University or law enforcement officials to investigate or respond effectively to the report;
(3) disclosure is required by law; or
(4) the person(s) accused of violations by the Whistleblower are entitled to the information as a matter of institutional due process in disciplinary proceedings.
Whistleblowers who reasonably believe that a University employee or student has retaliated against them may file a written complaint with the General Counsel, with a copy to the Vice President of People, Culture, and Community. If retaliation is substantiated, the retaliating employee(s) are subject to appropriate disciplinary actions or remedies, up to and including dismissal. The prohibition against retaliation is not intended to prohibit managers or supervisors from exercising legitimate supervisory responsibilities in the usual scope of their duties.
Related Documents
Related Content:
Revision Management
Revision History Log:
Revision #: |
Date: |
Recorded By: |
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v2.0 | 9/30/2024 2:12 PM | Pamela Mota |
v1.0 | 8/9/2019 3:38 PM | Jennifer Gilmore Adamo |
Vice President Approval:
Name: |
Title: |
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Mark Detterick | Vice President for Finance and Administration |