
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
Subject
|
Name
|
Title
or Position
|
Telephone
Number
|
Email/URL
|
Policy
Compliance Officer
College
Compliance Officer
College
Compliance Officer
|
Mark
Manning
Wendy
Tarby
Anastasia
Urtz
|
Senior Vice President and Chief
Financial Officer
Associate
Vice President
Vice
President
|
(315)
498-2268
(315)
498-2742
(315)
498-2962
|
m.r.manning@sunyocc.edu
tarbyw@sunyocc.edu
urtza@sunyocc.edu
|
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