Policies + Procedures — Governance + Compliance — Confidential Complaint Reporting

1.5 Confidential Complaint Reporting (Whistle-Blowing)

I. Purpose

The members of the Board of Trustees and college administration place the highest priority on ethical behavior as outlined in the college Code of Ethics found in policy 1.14 Ethics. To ensure both that a high standard of conduct is maintained and that employees have an avenue through which to voice concerns, this policy establishes a confidential complaint reporting mechanism.

II. Scope

All such complaints or comments made via the avenues outlined in this policy will be fully investigated, held in the strictest confidence and there will be no personal repercussions to the person making the complaint.

III. General

Any member of the college community may report, and is encouraged to report, concerns or complaints regarding behavior occurring during the conduct of college business which conflicts with the Code of Ethics. Items reported may include concerns or complaints referencing any of the following: failure to follow college policies and procedures, conflict of interest, neglect/inappropriate conduct of fiduciary duties, or financial issues such as questionable accounting practices, inadequate internal controls, and auditing matters.

IV. Procedures

Confidential complaints regarding the conduct of college business shall be reported to a staff member designated by the President in concurrence with the Audit Committee of the Board of Trustees.
No staff member or supervisor should conduct, directly influence or be involved in any investigative capacity in any inquiry into the activities of their own department or unit.
Should the designated staff member be the subject of the concern, or directly party to it, or should the person submitting the complaint prefer another reporting option, the complaint may be made to the President, the Chair of the Audit Committee of the Board or the Board Chair.
Persons submitting complaints may self-identify or remain anonymous. Such individuals may choose to report in person, in writing, or via a telephone number established for this purpose on which caller identity is blocked. Regardless of the reporting vehicle chosen, individuals are encouraged to provide as much detail as possible to ensure accurate understanding of the concern.
Persons initiating disclosures are protected by law from retaliation for disclosing any conduct that the employee reasonably believes violates provisions of Federal law or is unethical fiduciary behavior that may adversely affect the college. Protecting the identity of individuals who report will be a primary concern for investigators.
Upon receipt of a complaint, the designated staff member will notify immediately the Chair of the Audit Committee of the Board, the Board Chair, the President and Chief Financial Officer.
Under the direction and oversight of the Audit Committee of the Board, the designated staff member will coordinate the investigation of all complaints received. When appropriate, complaints will be referred for review and input to the Executive Director, Human Resources or College legal counsel.
Investigations shall be completed within 30 days of the receipt of the complaint unless extraordinary circumstances warrant an extension. More timely reporting may be requested by the Chair of the Audit Committee.
Following the completion of the investigation the designated staff member will submit a report to the Chair of the Audit Committee, the Board Chair, the President and Chief Financial Officer.
The report shall include investigation findings, complaint resolution and recommendations. Such recommendations may include notification of external authorities and, following consultation with the Executive Director, Human Resources, disciplinary action may be taken as appropriate. Should the President be a subject of the complaint, the recommendation shall be made directly to the Chair of the Audit Committee and Board Chair.
If the individual making the complaint or concern is identified, that individual will receive a response from the Executive Director, Budget & Internal Audit, or alternate as described above. The response shall indicate that the matter has been investigated and that a report/recommendation has been made to address the matter. The specific recommendation or action is not normally included in the response to the complainant.
The Audit Committee of the Board shall provide the Board of Trustees with an annual report summarizing confidential complaint activity.
The Audit Committee has the authority to retain external counsel, such as legal or accounting resources, as appropriate to address complaints received.