Policy B16
Policy Name: Whistleblower Policy
Responsibility for Maintenance: Financial Services

Date of most recent changes: June 16, 2015

I. Policy Statement

It is the responsibility of all officers and employees of the college to conduct themselves with honesty and integrity in matters regarding financial accounting, internal controls and auditing, and to report violations or suspected violations of these core values in accordance with this Whistleblower Policy. 

II. Reason for Policy 

This policy is designed to ensure that all officers and employees of the college conduct themselves with honesty and integrity in matters regarding financial accounting, internal controls and auditing, and that they report violations or suspected violations of these core values. It establishes procedures for the receipt, retention, and treatment of complaints received by the college regarding financial accounting, internal controls, and auditing matters and the confidential, anonymous submission by employees of complaints or concerns regarding such matters. 

III. Applicability of the Policy 

This policy applies to the submission of concerns or complaints regarding an officer’s or employee’s failure to conduct himself/herself with honesty and integrity in matters regarding financial accounting, internal controls and auditing. It does not apply to complaints or concerns involving other matters, which are instead subject to any college policies applicable to such matters.  

All members of the college community should be familiar with this policy.

IV. Contacts

V. Procedures 

Introduction

Onondaga Community College requires trustees, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the college, we must practice these core values in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

It is the responsibility of all officers and employees of the college to conduct themselves with honesty and integrity in matters regarding financial accounting, internal controls and auditing, and to report violations or suspected violations of these core values in accordance with this Whistleblower Policy. 

No Retaliation

No officer or employee who in good faith submits a report pursuant to this policy shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith pursuant to this policy is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the college.

Reporting Violations

The college maintains an open door policy and suggests that employees share their questions, concerns, or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor’s response, such employee is encouraged to speak with someone in the Human Resources Department or anyone in management whom the employee feels comfortable approaching. Supervisors and managers are required to convey such reports to the college’s Compliance Officer, who (except as described below and subject at all times to the oversight of the Finance, Audit and Compliance Committee of the Board of Trustees) has specific and exclusive responsibility to investigate reports. For suspected fraud, or when the forthcoming employee is not satisfied or uncomfortable with the open door policy, the college’s Compliance Officer should be contacted directly. If the forthcoming employee is not comfortable speaking with the Compliance Officer or if the Officer is not available and the matter is urgent, the forthcoming employee may contact the Chair of the Finance, Audit and Compliance Committee, and can obtain that person’s phone number from the Office of the President of the college. In addition, the college maintains a 24-hour, anonymous and confidential reporting service through a third-party organization to receive reports of issues and concerns. Reports may be submitted online at www.fraudhl.com (you will need to reference the Company ID: SUNYOCC) or by calling the following toll-free number: 1-855-FRAUD-HL (1-855-372-8345).

Compliance Officer

The college’s Senior Vice President and Chief Financial Officer is the college’s Policy Compliance Officer. The college’s Policy Compliance Officer is responsible for investigating and resolving all reports submitted pursuant to this policy (subject to direct reporting to the Chair of the Finance, Audit and Compliance Committee as described above) and, at the Officer’s discretion, shall advise the President and the Finance, Audit and Compliance Committee. The Policy Compliance Officer has direct access to the Finance, Audit and Compliance Committee of the Board of Trustees and is required to report to the Finance, Audit and Compliance Committee at least annually on compliance activity. 

Acting in Good Faith

Anyone filing a complaint pursuant to this policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent reasonably possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Policy Compliance Officer (or the Chair of the Finance, Audit and Compliance Committee, if a report is submitted directly to him/her) will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. 

Approved by OCC Board of Trustees April 3, 2006

Updated and approved by the OCC Board of Trustees June 16, 2015