Whistleblower Policy

Agnes Scott College is committed to living honorably and to providing members of the campus community with "opportunities for ethical reflection, deliberation, and action." In line with this commitment, the college expects all employees to perform their duties in accordance with applicable laws and regulations, college policy and procedures and high ethical standards. It is committed to compliance with all applicable laws and regulations and seeks to promulgate and administer college policies and procedures that faithfully apply such laws and regulations. A culture of compliance promotes ethical practices and creates a foundation for the honorable treatment of all members of the college community and those who conduct business with the college.

1. Purpose

The purpose of this policy is to encourage and enable good-faith reports by college employees and others of observed or suspected misconduct or noncompliance with law or with college policies and procedures.

2. Scope

This policy is intended to encourage and enable employees and others who have good-faith serious concerns about misconduct, including violations of law, regulations or college policies and procedures or other conduct ("misconduct") to raise them with the college before seeking external resolution. This policy is not intended to supplant, but rather to complement and supplement, existing college policies. It thus does not affect any rights, responsibilities or procedures set forth in other college policies addressing misconduct. For example, complaints or grievances such as those regarding discrimination or harassment, other personnel and employment matters, academic and disciplinary matters, academic freedom, research misconduct and other matters as to which there are specific college policies should ordinarily be made and addressed in accordance with the college policies applicable to such matters and applicable law.

3. Reporting Responsibility

Each member of the college community shares responsibility for stewardship of college resources and compliance with laws and policies. Therefore, college faculty, staff and students are encouraged to report, in accordance with this policy, any misconduct by college employees or actions of other parties that may result in financial loss or other harm to Agnes Scott College of which they may become aware. For purposes of this policy, a Reporting Person is any employee or student who makes a report under this policy.

4. Guidance on Reporting

An employee who has a question about the propriety of any practice under college policies or procedures should ordinarily seek guidance from his or her supervisor or a college official with compliance oversight responsibility for the particular policy or procedure. An employee may also seek guidance from the vice president for business and finance or the director of human resources.

5. Confidentiality

A Reporting Person may request that a report made under this policy be handled as confidentially as possible under the circumstances. Although the college will endeavor to handle all such reports with discretion and due regard for privacy, other obligations and considerations may preclude the college from maintaining confidentiality in all circumstances.

6. Anonymous Reports

A Reporting Person may make an anonymous report. However, it should be understood that any investigation may be hampered or be impracticable if the Reporting Person cannot be identified and questioned about the allegations and related facts.

7. Persons to Whom Reports May Be Made

A Reporting Person ordinarily should report suspected misconduct to his or her immediate supervisor. If the Reporting Person feels it is inappropriate to report to an immediate supervisor, the Reporting Person should raise the issue with another person with supervisory authority, such as his or her manager, department chair, dean, director or the college officer or official responsible for overseeing compliance with the policy or procedure at issue. If a Reporting Person believes further reporting is appropriate, a written report under this policy may be made to the following offices:

Reports about a staff member may be filed with the college's Office of Human Resources, Attn: director of human resources.

Reports about a faculty member may be filed with the Office of the Dean of the College, Attn: vice president for academic affairs and dean of the college.

Reports about a student may be filed with the Office of the Dean of Students, Attn: vice president for student life and dean of students.

Reports involving the president, a vice president or a trustee of the college, or any report concerning accounting practices, finances, internal controls, inappropriately managed conflicts of interest and/or auditing may be submitted to the chair of the Audit Committee of the Agnes Scott College Board of Trustees, by submitting the report, in an envelope addressed to the Chair of the Audit Committee, to the Office of the Secretary of the Board. Reports submitted in this manner will be delivered to the chair of the Audit Committee for evaluation.

8. No Retaliation

No individual who in good faith reports a violation or suspected violation shall thereby suffer harassment, retaliation or adverse employment and/or academic or educational consequences. An employee who retaliates against someone who has made a report in good faith under this policy is subject to disciplinary action, up to and including dismissal from the college. Individuals who believe they have suffered retaliation may report it to one of the reporting venues identified above.

Reports made in bad faith or with knowledge of their falsity may subject individuals to disciplinary or other appropriate action. Making a report under this policy shall not insulate an individual from personnel or other actions that are warranted based on performance or other factors and are not caused by the making of a complaint under this policy.

9. Document Retention

The Office of the Vice President for Business and Finance will document the processing and, as appropriate, resolution of reports made under this policy and shall retain such documents in a secure location.

10. Resolution of Reports of Misconduct

Reports of misconduct submitted to members of the campus administration listed in section 7 of this policy shall be reviewed by the president in consultation with the other officers of the college. The college officers will decide on a course of action to investigate and resolve the matter in accordance with applicable college policies and procedures and will take corrective action as warranted.

Reports submitted to the chair of the Audit Committee of the Board of Trustees shall be reviewed by the Audit Committee in executive session. The Audit Committee shall exercise discretion in determining whether to conduct further review, initiate an investigation, refer the matter to a college office or take other steps as warranted.

When a case has been resolved, a brief report on its resolution shall be shared with appropriate individuals or departments as well as with the Reporting Person. An annual report on all cases submitted to college officers under this policy shall be shared with the Audit Committee.

The vice president for business and finance is responsible for implementing this policy. Ultimate responsibility for oversight of this policy rests with the Audit Committee of the Board of Trustees.

Policy No.  898  Issued  3/1/2012