Whistleblower (Employee Protection)

(Approved by Executive Council November 09, 2021)

It is the intent of the University to adhere to all laws and regulations that apply to the University and all employees are expected to share in this commitment. The support of all employees is necessary to achieve the University’s goal of legal and ethical compliance. The university will not retaliate against an employee who in good faith has filed such a complaint, bringing the alleged unlawful policy, practice or activity to the attention of the University in accordance with this policy. Any complaint or report of an alleged violation of the University’s Equal Opportunity, Nondiscrimination, Sexual and Other Forms of Harassment Policy shall be handled in accordance with the Equity Discrimination Resolution Process. (See Section 8.0)

Reporting Responsibility
This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that St. Mary’s University can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of St. Mary’s University’s code of ethics or suspected violations of law or regulations that govern St. Mary’s University operations.

No Retaliation
It is contrary to the values of St. Mary’s University for anyone to retaliate against any board member, officer, employee, or volunteer who, in good faith, reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of St. Mary’s University. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to, and including, termination of employment.

Reporting Procedure
St. Mary’s University has an open door policy and suggests that employees share their questions, concerns, suggestions, or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Executive Director of Human Resources. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Executive Director of Human Resources who has the responsibility to investigate all reported complaints. If the concern is related to the Office of Human Resources, concerns should be directed to the Vice President of Administration and Finance. If the matter is concerning the Vice President of Administration and Finance, the matter should be reported to the Office of the President. Any matter specifically related to financial concerns should be reported to the Associate Vice President of Finance and/or the Vice President of Administration and Finance.

The Office of Human Resources
The Executive Director of Human Resources is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Office of Human Resources will advise the Vice President of Administration and Finance of all complaints and their resolution whenever notified of an alleged violation. The Vice President of Administration and Finance will report at least annually to the University Executive Council on alleged concerns and will report significant allegations relating to accounting or alleged financial improprieties to the Audit and Ethics Committee and the Chair of the University Board of Trustees.

Accounting and Auditing Matters
The Vice President of Administration and Finance shall promptly notify the Audit Committee/Finance Committee of any legitimate concerns or significant, founded complaints regarding institutional accounting practices, internal controls, or auditing and work with the committee until the matter is resolved.

Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense and subject to disciplinary actions that may include termination of employment.

Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations
The Executive Director of Human Resources will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.