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Main Menu About the Internal Audit Department Types of Services FAQs Ethics and Compliance Hotline (This hotline is independently operated to help ensure confidentiality) What is Fraud? Whistleblower Policy What is Risk Assessment? What is Internal Control? Links of Interest Policies Governing Internal Audit |
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"Whistleblower" Policy The general purpose of this policy is intended to protect any employee who engages in good faith disclosure of alleged wrongful conduct to a public body or to a designated College official. More specifically it:
Statement of Policy. College employees are expected to abide by applicable state and federal laws. Furthermore, an employee cannot be compelled by a supervisor or College official to violate a College policy, an applicable law, or public policy. In the interest of the College, an employee who has particular knowledge of specific acts which he or she reasonably believes constitute wrongful conduct should disclose the conduct to the appropriate College official. If an adverse employment action is taken against a College employee in knowing retaliation for his or her good faith disclosure of information to a designated College official concerning alleged wrongful conduct, as defined under this policy, and if the employee's work performance or behavior did not warrant the adverse action, then the College should take remedial action for the employee and corrective action against the supervisory employee. The College shall devise procedures for handling disclosures and responding to complaints of reprisal or retaliation, as long as such procedures conform to the guidelines detailed below. These procedures should be published in College and campus handbooks, as well as on applicable websites. Wrongful Conduct Wrongful conduct is defined in this policy to be:
Disclosure and Disclosure Investigation Where the College has defined policies and procedures for maintaining standards of conduct and disclosure of such violations, the applicable College policies should be followed to disclose such violations. Relevant policies include but may not be limited to:
In matters relating to wrongful conduct as defined in the section above, mismanagement of College resources, or an abuse of authority which is not covered by specific College policy, each campus should designate a campus or College official to receive such disclosures and to ensure that there is an investigation of the disclosure (hereinafter referred to as a "disclosure investigation"). The responsible designee who receives a disclosure whether pursuant to a College policy or as the campus designee, should maintain a written record of the allegation and conduct an investigation or ensure that the appropriate unit (College auditors, campus police, etc.) investigates the disclosure. In the event that the identity of the employee making the disclosure is known, upon the conclusion of the investigation the appropriate designee will notify, in writing, the employee or employees who made the disclosure of the determination and retain a copy of that notification. Similarly, where an individual has knowledge that he or she is being investigated for wrongful conduct, that individual should be notified of the determination of the disclosure investigation at a time considered to be appropriate by the designee so that any notice would not compromise any further actions deemed appropriate by the investigating officer. A complaint of reprisal for disclosure requires an adverse employment action as a result of the disclosure before it can be pursued as a complaint of reprisal. In matters of disclosure, the College official will attempt to maintain the identity of the employee making the disclosure in a confidential manner, as long as such maintaining this confidentiality does not interfere with conducting an investigation of the specific allegations or taking corrective action. Complaints of Reprisal
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