Whistleblower Policy

Article I: Summary

Hope College (the 亚洲色吧淐ollege亚洲色吧�) requires all employees (including faculty) to observe very high standards of business and personal ethics in the conduct of their duties and responsibilities. The College亚洲色吧檚 internal controls and operating procedures are intended to detect and prevent or deter violations of law, applicable governmental rules and regulations, and College Policy (collectively 亚洲色吧淰iolations亚洲色吧�). However, even the best systems of control cannot provide absolute safeguards against Violations. The College provides various mechanisms to assist and encourage employees to come forward in good faith with reports of Violations or suspected Violations. It is the policy of the College to encourage reporting of suspected Violations on a timely basis.

Article II: Whistleblower Procedure

Although the College encourages employees to report concerns to their immediate supervisor, the college acknowledges there are times when an employee may feel it is necessary to report a Violation outside of the traditional reporting chain of command. The College has adopted a Whistleblower Procedure for these instances. The Whistleblower Procedure allows allegations to be made outside of the immediate area that the suspected employee is associated with and allows for a degree of confidentiality for the reporting person, if requested. This Whistleblower Procedure governs only the reporting and investigation of suspected Violations. Such Violations may include, but are not limited to:

Theft or inappropriate use of cash or other College property
Falsification of hours worked for payroll purposes
Inappropriate spending of cash through the accounts payable or credit card processes.

The Procedure is not to be used for personal or employment grievances, general compensation and benefit complaints, opinions on policy, etc. To make a report under this policy an employee must complete and sign a Whistleblower Report either in the Human Resources office or online. Reporting of the Violation can be made as follows:

In Person: Employees may visit the Director of Human Resources during standard operating hours to file a report, or make arrangements for an appointment during non-standard operating hours. The Human Resources office is located in the Anderson/Werkman building and can be contacted at x7811.
Mail: Employees may send to the Director of Human Resources a completed Whistleblower Report. The employee may need to visit the Human Resources office to answer any questions concerning the report.

Employees should be aware that the filing of a report may result in an investigation of the suspected Violation and acknowledge that in their report. Since successful investigations are often based upon timely evidence, reports under this policy should be made as soon as possible. Employees may report suspected Violations anonymously but are encouraged to identify themselves to aid in the investigation.

Article III: Protection from Retaliation

An employee who in good faith reports a suspected Violation shall not be discriminated against or suffer harassment, retaliation or adverse employment consequences from other employees or the College as a result. An employee who retaliates against someone who has reported or is about to report a suspected Violation in good faith is subject to discipline up to and including termination of employment. Any employee who believes that they have been retaliated against after making a good faith report should report this alleged retaliation to the Director of Human Resources.

Article IV: Confidentiality Under the Whistleblower Policy

The College will endeavor to maintain the confidentiality of the reporter to the extent possible within the limitations of the law, College policy and the legitimate needs of the investigation. In addition, employees submitting a report should be aware that their public testimony might be needed to prove the suspected Violation. Although an employee亚洲色吧檚 report may possess merit, comments made to others regarding the suspected violator are not privileged. Employees are encouraged to not discuss allegations outside of the reporting and investigation process. This is especially true should the investigation prove that the suspected Violations were lawful or within College policy.

Note that if an employee self-discloses his or her identity directly or indirectly outside of the reporting procedure through his or her own actions, it will be difficult for the College to maintain confidentiality.

Article V: Investigation Under the Whistleblower Policy

The Director of Human Resources will maintain the Whistleblower Reports received in their office until the outcome of the investigation. The Director of Human Resources will not actively participate in an investigation, but will refer the allegation to the appropriate office (dependent on the specific circumstances, but typically to the CFO, Provost, appropriate Vice President, and/or the Director of the applicable office of the suspected violator). The investigator/investigation team will investigate reported Violations promptly and with reasonable diligence.

Should the allegation be against the CFO, Provost or a Vice President, the President of the college will lead and develop the investigation team if necessary.

Should the allegation be against the President, the CFO along with the Chairperson of the Board of Trustees will conduct the investigation.

The investigator/investigation team is responsible for documenting results of its investigation and its rationale for the resolution. That document will be attached to the original Whistleblower Report and reside in the Human Resources office

during the investigation. The investigation is closed when the Director of Human Resources has deemed the investigation is complete and a result reported by the investigator/investigation team. Documents and evidence relating to a closed investigation will remain in the College亚洲色吧檚 files in the Human Resources office.

Article VI: Results When Report Made Under the Whistleblower Policy

If the result of the investigation is that the Violation is not satisfactorily established, the investigation will be deemed complete. An employee whose claim is not confirmed by investigation has the opportunity to communicate directly with the Office of Human Resources outside of this policy to further pursue their claim.

If the investigation establishes that a Violation has occurred, the CFO, Provost, appropriate Vice President, the Director of Human Resources and the Director of the applicable office of the investigated employee will determine appropriate response to the Violation. Should the violator be one of the above mentioned personnel, the President will replace that person in the decision process. Should the President be the violator, the Chairman of the Board of Trustees will become a part of this decision process.

Whistleblower Reports and related documentation will be delivered to the President by the Director of Human Resources and they will report all significant Violations to the Board of Trustees. Should the President be the violator, the Chairman of the Board of Trustees will disclose the violation to the Board of Trustees.

Article VII: Sanctions for a False Report

A report made under this policy can have considerable impact on the personal and professional lives of those charged both during the investigation and long term. An employee shall not intentionally misuse the College亚洲色吧檚 Whistleblower

Policy and procedures. Intentional misuse includes, but is not limited to, frivolous claims, attempts to treat a personal grievance or personnel dispute as an allegation of wrongdoing, lack of good faith in invoking the policy or any known false, malicious or misleading statements made at any time under the procedures of the policy. The College亚洲色吧檚 Director of Human Resources will report to the Vice President and/or the Director of the applicable office of the employee the identity of any employee who is believed to have intentionally misused the Whistle Blower Policy. After appropriate review by these individuals the employee is subject to discipline up to and including termination.

Last updated: October 23, 2024

Owner: Human Resources