ࡱ> @B?#` +bjbj\.\. .(>D>D%BBBBBBBV 8  V: P "r r r MMM]______$h!XBMMBBr r dBr Br ]]rTBBr . UB p9$0T"pT"T"BM0}"MMM`dMMMVVV VVV VVVBBBBBB HR: 4190, p. 1 Whistleblower Protection Scope: This policy applies to all persons. Definition: Protected Disclosure means an allegation, made in good faith, that the College or one or more of its employees, contractors (acting in the course of its work for the College) or members of the Board of Trustees, has in the course of his, her or its duties to the College acted unlawfully or in violation of published Board of Trustees or college administrative policies. Policy: The 鶹ֱ, as a public agency, has moral, ethical and legal responsibilities for the stewardship of its resources and the public and private support that enables it to pursue its mission. Although the Colleges internal controls and operating procedures are intended to deter, detect and prevent improper activities, as at any institution of this size, intentional and unintentional violations of laws, regulations, and policies may occur. The College has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities, and to protect those persons who, in good faith, report these activities to the appropriate authority. The College and its employees are prohibited from 1) retaliating or attempting to retaliate against any person who has made a Protected Disclosure or who has refused to obey an order that is illegal or in violation of published Board of Trustees or college administrative policies, and from 2) directly or indirectly using or attempting to use the authority or influence of his or her position for the purpose of interfering with the right of the person to make a Protected Disclosure. Procedure: Any person may make a Protected Disclosure. Protected Disclosures should be made in writing so as to assure a clear understanding of the issues, but may be made orally. Such reports should be factual and contain as much specific information as possible. Protected Disclosures that are covered by the policy on Protection from Discrimination, Sexual and Other Harassment and Retaliation (HR 4130) are to continue to be made to the persons set forth in that policy. HR: 4190, p. 2 Normally, other Protected Disclosures should be made 1) by employees to their immediate supervisor or other person in the supervisory chain, and 2) by other persons to the Vice President and General Counsel. However, when there is a potential conflict of interest or for other reason, such reports may be made to another College official, at a director level or above, whom the reporting person may reasonably expect to have either responsibility over the affected area or the authority to review the alleged improper activity on behalf of the College. All employees who receive such reports shall immediately report them to the Vice President and General Counsel (or if the Vice President and General Counsel is implicated, to the President) who will participate in the investigation. If the alleged improper activities involve the President, such reports should be made to the Vice President and General Counsel. Protected Disclosures in most categories can also be made anonymously through the colleges third party compliance line at  HYPERLINK "https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=15726" https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=15726 or 888-552-8064. The Vice President and General Counsel will inform the Board Affairs committee of all Protected Disclosures alleging questionable accounting, auditing or internal fiscal controls and will provide the committee with a follow-up report on actions taken in response. All internal complaints will be investigated promptly and with 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. For more information contact: Vice President and General Counsel, ext. 7643. 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