Whistleblower Policy

Policy Number: 300.002.02
Approved by: Senior Staff
Effective Date: April 2013

This Whistleblower policy is designed to enable all of the College’s faculty and staff to report concerns about possible financial misconduct, with reassurance that they will be protected from retaliation for acting in good faith.

Purpose

Scripps College is committed to the highest standard of financial conduct. This policy is designed to enable all of the College’s faculty and staff to report concerns about possible financial misconduct, with reassurance that they will be protected from retaliation for acting in good faith. Reports on financial misconduct would address such issues as accounting discrepancies, fraud, accounting misrepresentations, audit matters, accounting omissions, ethics violations or other financially related matters.

Background

Scripps College prides itself on maintaining high ethical standards in all dealings with the business community, the public, the College community, and fellow employees. Scripps has certain policies essential to maintaining these standards – Scripps College Mission Statement, Principles of Community and the Guide to Student Life. All of those who work for Scripps College are aware of our commitment to these standards, and we will work hard to meet them. However, to formalize our commitment to certain critical policies, our Board of Trustees has adopted a Code of Business Ethics. A short form code of conduct is applicable to all employees and a long form is applicable to all employees at a Director level or higher.

Policy 

All reports of suspected financial misconduct by Scripps College employees or trustees could be made confidentially and directly to either the Chair of the Audit Committee of the Board of Trustees, the College’s Chief of Staff or the College’s Director of Human Resources. The College’s Chief of Staff shall oversee the receipt, retention and resolution of such reports.  The Chair of the Audit Committee will work with the Chief of Staff, the Administration and outside advisors to ensure that these reports receive the appropriate attention.  Any employee ultimately found to have engaged in financial misconduct is subject to disciplinary action by the College, which may include dismissal as well as prosecution by appropriate law enforcement authorities.

The protection of employees who submit reports of suspected financial misconduct is an important part of this policy, as is maintenance of the confidentiality, objectivity and independence necessary to resolve complaints appropriately.  The Chair of the Audit Committee, Chief of Staff, Director of Human Resources and the Administration share responsibility for maintaining these features of the policy, although, depending on the nature of the discipline or the actions of law enforcement agencies, this confidentiality cannot be guaranteed.

It is a violation of this policy to knowingly make fraudulent allegations of financial misconduct with the intent to cause harm to another individual.  Those making such allegations are also subject to disciplinary action, up to and including termination.

Accountability

Chief of Staff

Applicability

This policy applies to all employees.

Procedure

Since confidentiality is an important part of this policy, the College has contracted with an outside reporting service called MySafeCampus to facilitate the transmission of reports of financial misconduct to the Chief of Staff and the Chair of the Audit Committee of the Board of Trustees. Reports may be made by accessing the website (www.MySafeCampus.com) or by calling the toll-free number (1-800-716- 9007). Both methods are available 24 hours a day, seven days a week.  Upon submission, the reporting party is provided with a confidential access number and is asked to generate a personal password that provides access to the status of the report.  The reporting party may also send and receive anonymous messages pertaining to his/her report.  To expedite an efficient investigation, it is recommended that the reporting party respond as soon as possible to any follow-up questions posted on the message board from the Chief of Staff and/or the Chair of the Audit Committee.

When a reporting party makes a report, he or she will be asked to choose among three levels of anonymity: anonymous to both the College and MySafeCampus; anonymous to the College but not to MySafeCampus; or known to both parties.  The report should contain as much detailed information about the incident(s) as possible in order to facilitate an efficient and thorough investigation. This detail should include, at a minimum, the names of the parties involved, the location of the incident(s) and the nature of the possible financial misconduct.  Once a report is made, it is important for the reporting party to check the status of the report periodically, because if the respondent requires additional information, a message will be posted on the MySafeCampus message board for follow-up by the reporting party. If the additional information is not provided, the investigation may be deemed inconclusive and, therefore, result in no action.

The Chief of Staff, working in conjunction with MySafeCampus, shall prepare periodic summaries of complaints received by categories of complaints, including accounting, internal accounting controls, or auditing matters for review by the Audit Committee.  As appropriate, reports regarding the status of specific complaints may be reported on a more frequent basis.

Questions

Any questions regarding this policy should be directed to the Chief of Staff or the Director of Human Resources.