This policy is intended to encourage and enable employees to raise serious concerns relating to the financial affairs or the financial record keeping (“Financial Affairs”) of the College within the organization, for investigation and appropriate action. With this goal in mind, no employee who, in good faith, reports such a concern shall be threatened, discriminated against, or otherwise subject to retaliation or adverse employment consequences as a result of such report.

The following concerns are covered by and may be reported under this policy:

• providing false or misleading information on the College’s financial documents, tax returns or other public financial document;
• providing false material financial information to, or withholding such information from, the auditors, accountants, lawyers, trustees or other parties responsible for ensuring the College’s compliance with fiscal and associated legal responsibilities;
• violation of any law relating to the financial affairs of the College, including embezzlement, private benefit, or misappropriation of funds;
• material violation of the Board of Trustees’ policy on conflict of interest.

Procedures to Report Concerns

An employee may report a concern covered by this policy directly to the President, the Chief Financial Officer, the Provost and Dean of the College, or the Director of Human Resources. However, if for any reason an employee is not comfortable reporting to any of these individuals or does not believe the issue is being properly addressed, the employee may report the matter to the Chair of the Board or any member of the Board of Trustees. A report must be in writing.

Handling of Reported Concerns

The College will investigate promptly any report made in accordance with this policy. A matter reported to any of the four staff members referred to above will be investigated to determine whether the allegation is true, whether the issue is material, and what actions, if any, are necessary and appropriate to correct the problem.

A matter reported directly to the Chair of the Board or any member of the Board of Trustees will be investigated by the Chair or her/his designee, unless the matter pertains to the Chair. The Chair or her/his designee will investigate to determine whether the allegation is true, whether the issue is material, and what, if any, corrective action is necessary and appropriate. If the report pertains to the Chair, the President will investigate to determine whether the allegation is true, whether the issue is material, and what, if any, corrective action is necessary and appropriate.

Acting in Good Faith

An employee reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a serious violation of law or policy relating to the Financial Affairs of the College, or a material accounting or auditing matter.

Confidentiality

Reports of concerns, and investigations pertaining thereto, shall be kept confidential to the extent practicable and permitted by law.