Whistleblower Policy

Introduction and Responsibility

Albion College is committed to maintaining the highest ethical standards. All members of the College community have a responsibility to report violations or suspected violations of laws, regulations, College policy or procedure, inappropriate behavior regarding business practices, accounting or bookkeeping, or use of institutional resources. The College has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities and to protect those employees, who, in good faith, report these activities to the proper authority.

Reporting

Normally, a report by a College employee of allegations of suspected improper activity should be made to the reporting employee’s immediate supervisor or other appropriate administrator or supervisor within the operating unit. However, when there is a potential conflict of interest, such reports may be made outside of the traditional reporting mechanism. Reports may be made in person, by mail or via the Campus Conduct Hotline©. Such a report is known as a protected disclosure. College employees and applicants for employment who make a protected disclosure are protected from retaliation. The Campus Conduct Hotline© system is available for use around the clock, seven days a week. Because the Hotline is operated by an independent organization, any tips made through this Hotline are completely confidential and anonymous. The Campus Conduct Hotline© can be reached, toll-free at (866) 943-5787. Communications made in person may be made to Internal Audit.

Submit written reports in a sealed envelope directed to Internal Audit marked “Confidential – Fraud Policy”. Sufficient information should be provided in order that an investigation may be conducted. This report may be submitted anonymously. Written reports will be forwarded, unopened, to the Chairman of the Audit and Compliance Committee of the Albion College Board of Trustees.

Process of Investigation

Allegations will be forwarded to the Chair of the Audit and Compliance Committee of the College’s Board of Trustees who will initiate the investigation. The Audit and Compliance Committee may enlist outside legal, accounting, or other advisors, as appropriate to conduct any investigation. If the investigation establishes that a violation of law, external regulation or College policy occurred, appropriate action will be based upon law and College policy.

Protection to whistleblowers and penalties to retaliators

Whistleblowing complaints will be handled with sensitivity, discretion, and confidentiality to the extent allowed by the circumstances and the law. Generally this means that whistleblower complaints will only be shared with those who have a need to know so that the College can conduct an effective investigation, determine what action to take based on the results of any such investigation, and in appropriate cases, with law enforcement personnel. Should disciplinary or legal action be taken against a person or persons as a result of a whistleblower complaint, such persons may be entitled to the information as a matter of institutional due process in disciplinary proceedings.

Whistleblowers who believe that they have been retaliated against may file a written complaint with Internal Audit. Any complaint of retaliation will be promptly investigated and appropriate corrective measures taken if allegations of retaliation are substantiated. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.

The College will take the appropriate action to prevent and correct violations of this Whistleblower Policy; such action shall be in accordance with applicable laws and regulations, College policies and procedures, and any applicable collective bargaining agreements. All internal complaints will be investigated promptly and with the discretion, and all information obtained will be handled on a “need to know” basis. At the conclusion of an investigation, as appropriate, remedial and/or disciplinary action will be taken where the allegations are verified and/or otherwise substantiated. An employee who retaliates against someone who has reported or suspected violation in good faith is subject to discipline up to and including termination of employment.