Whistle Blower Policy
(Approved by Finance Council February 1, 2008)
Houghton College has a deep commitment to responsible stewardship of the resources, financial and otherwise, that are entrusted to us by our various constituencies and that enable us to pursue our mission. We are committed to compliance with the laws and regulations to which we are subject and to promulgating policies and procedures to interpret and apply these laws. Most importantly, as a Christian institution, Houghton College is committed to conducting ourselves in an upright, moral and biblical manner.
The college’s internal controls and operating procedures are intended to detect and to prevent or deter improper acts. However, even the best systems of controls cannot provide absolute safeguards against irregularities. Intentional or unintentional violations of laws, regulations, policies and procedures may occur and may constitute improper activities. Therefore, employees have the responsibility to report suspected improper activities and the College has a responsibility to thoroughly investigate any allegations received.
The College’s Compliance Officer is:
Executive Director, Human Resources
1 Willard Ave.
Houghton, NY 14744
On-Campus extension: 3210
Office Location: 1st Floor Luckey Building
Employees or other individuals wanting to report suspected improper activities may do so by one of several methods:
- Contact the Compliance Officer to set up a meeting to discuss the concern.
- Submit your concern in writing. A sealed envelope can be sent to the Compliance Officer by intra-campus or U.S. mail. While we would prefer that you use your name in case additional details are needed, the allegation will still be thoroughly investigated if it is submitted anonymously.
Should the concern involve an allegation against the Compliance Officer it should be directed to the President.
Relevant concerns may include but not be limited to:
- Any misrepresentation of the true financial state of affairs of the College
- Financial irregularity, fraud, theft, corruption, bribery, dishonesty (including such things as mis-use of college credit card, falsification of expense reports, etc.)
- Any illegal act
- Directing another employee to perform any of the above
- Deliberate concealment of any of the above
No individual who in good faith reports a concern shall suffer harassment, retaliation or adverse employment consequences. An employee who retaliates against someone who has reported a concern in good faith will be subject to disciplinary action, up to and including discharge. Any employee who believes they have been retaliated against should contact the Compliance Officer.
Investigation of Concerns Received
Every allegation will be investigated promptly. Upon receiving a report of suspected improper activity, the Compliance Officer will immediately begin an investigation in conjunction with the appropriate Vice President. If the allegation is directed towards a Vice President, the Compliance Officer will begin an investigation in conjunction with the President. If the allegation is directed towards the Compliance Officer, the President shall begin an investigation. If the allegation is directed towards the President, the Compliance Officer will contact the Chair of the Board of Trustees (or if unable to contact the Chair the Vice Chair) and jointly they will decide how to proceed with an investigation. Regardless as to who the allegation is directed towards, the Compliance Officer has direct access to the President and the Chair (or Vice Chair) of the Board of Trustees at any time if he believes the concern is not being addressed appropriately at the Vice Presidential or Presidential level. The Compliance Officer and the appropriate administrative officer investigating the allegation (Vice President, President, Chair or Vice Chair of Board of Trustees) have the authority to include the appropriate campus committee representatives (staff cabinet, rank and tenure, faculty affairs, etc.) as they deem appropriate.
Distribution of Policy
The Compliance Officer shall be responsible for assuring that a copy of this policy is made available to all employees.