Columbia College is committed to lawful and ethical behavior and expects members of the College community (which includes, but is not limited to students, employees, Trustees, etc.) to act in accordance with all College policies as well as with all applicable laws, rules, and regulations. The purpose of this policy is to encourage College employees - and all members of the College community - to report what they, in good faith, believe or suspect to be violations of College policy, violations of law, dishonesty, fraud, or other misconduct (collectively referred to herein as "Wrongful Conduct") and to protect the person making the report (i.e., "whistleblower") from retaliatory action.
A. Activities to Report
The College encourages reports of suspected Wrongful Conduct, which can include, but is not limited to, the following:
- Theft, misuse, or other misappropriation of College property, resources, or assets;
- Mismanagement or waste of College funds or College-related funds;
- Improper records destruction;
- Providing inaccurate, false or misleading information;
- Unethical activities;
- A substantial and specific danger to public health or safety;
- Violation of any law, regulation, rule, policy, etc.;
- Forgery or unauthorized alteration of documents; and
- Concealing any of the above actions.
B. Reporting Procedure
An employee, or other member of the College community, wishing to make a report of Wrongful Conduct under this policy should do so to an appropriate College supervisor as soon as he or she becomes aware of such conduct. The supervisor is then expected to immediately forward the report to the Office of the General Counsel. If, for any reason, an employee finds it difficult to make a report to a supervisor, he or she may file the report directly with the Executive Director of Human Resources or with the Office of the General Counsel.
A report involving Wrongful Conduct by the President, Executive Director of Human Resources or by the Office of the General Counsel should be reported as follows:
- If the subject of the report is the Executive Director of Human Resources or the General Counsel, the report should be made to the President.
- If the subject of the report is the President, the Executive Director of Human Resources or the Office of the General Counsel will immediately notify the Chair of the Board of Trustees ("Board Chair") upon receipt of the report.
To preserve the integrity and effectiveness of an investigation into an allegation of Wrongful Conduct, individuals making a report should refrain from discussing the situation with anyone other than the person to whom the report was made and with appropriate individuals designated by the College during the investigation of the matter. Likewise, a supervisor forwarding on a report should not further discuss the matter other than with appropriate College personnel as directed by the College. The exception to this section is in instances of potential criminal conduct, in which case complaints may also be reported to appropriate law enforcement officials or external entities.
C. Good Faith Reporting
An individual making a report must do so in good faith and have reasonable grounds for believing/suspecting Wrongful Conduct is involved. Individuals making reports are not expected to and should not conduct their own investigation prior to making a report; however, making allegations that are knowingly false will be viewed as a serious offense and may result in discipline, up to and including termination.
D. Anonymous Reporting
Anonymous and confidential reports can be submitted online or by calling or faxing 1-855-FRAUD-HL (1-855-372-8345). The following Company ID will be required to submit your report: CCIS. It is essential that anonymous reports contain as much specific information as possible to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations will not be undertaken without reasonable and verifiable evidentiary support. In addition, since an investigation of an anonymous report will not include an interview with the reporting individual (because they are anonymous), it may be more difficult to evaluate the credibility of the allegations. Therefore, the nature of anonymous reports may decrease the likelihood of the College's ability to conduct a full investigation into the alleged Wrongful Conduct.
Following the receipt of a report, the College – or the Board Chair in the case of a report made about the President – will appoint an appropriate investigator(s) trained in conducting investigations and free from any conflicts of interest (the College may engage outside legal counsel for these service) who will conduct a preliminary assessment and determine whether an investigation should be commenced based on the facts provided. Prior to initiating a preliminary assessment or investigation, consideration will be given to whether or not the matter should involve law enforcement authorities and whether or not law enforcement authorities should be contacted before proceeding. If an investigation is deemed appropriate, an internal and/or external investigator(s) will proceed with an investigation. The scope and timing of the investigation will vary by circumstance, but an investigation will generally involve a review of relevant documents and other records (e.g., physical documents, emails, browser histories, voicemails, text messages, etc.) and interviews with individuals who may have knowledge of the situation.
If through the course of an investigation the College determines that Wrongful Conduct has occurred, a written finding will be presented to the appropriate College senior administrator(s) or Board for appropriate responsive action. Responsive action will be based, in part, on the nature and scope of the Wrongful Conduct.
A person making a report of Wrongful Conduct may be informed of the disposition of the report and the findings of any investigation, although there may be reasons, such as legal limitations/consideration, not to do so. Additionally, any action taken against an employee as a consequence of the findings of an investigation may be personal and confidential, in which case the reporter will not be informed of such consequences.
Reports of suspected Wrongful Conduct, and investigations of such reports, shall be kept confidential to the extent possible. However, consistent with the need to conduct an adequate investigation, the College cannot guarantee complete confidentiality. Disclosure of information related to a report and investigation by College personnel to other uninvolved individuals will be viewed as a serious offense and may result in discipline, up to and including termination.
V. No Retaliation
The College will use its best efforts to ensure that an employee who, in good faith, reports actual or suspected Wrongful Conduct does not suffer an adverse employment action or other retaliation as a result of making such report. An employee who retaliates against another employee for making a good faith report of Wrongful Conduct, or for participating in an investigation, is subject to discipline, up to and including termination.
Questions regarding this policy should be directed to the Office of the General Counsel (email@example.com) or to the Human Resources Office (firstname.lastname@example.org).