Purpose of the Whistleblower Policy
Colgate University (“the University”) is committed to appropriately protecting its physical, financial and human resources and complying with all applicable laws and regulations. The University expects trustees, officers, employees and associated volunteers (collectively the “individuals”) to comply with all applicable laws and regulations as well as all policies adopted by the University. This Whistleblower Policy is designed to further that objective.
Duties and Responsibilities
Pursuant to its responsibility to oversee University governance, the Board of Trustees has authorized the establishment of procedures for the protection of individuals who come forward in good faith to bring information on possible illegal or fraudulent practices or violations of University policy to the attention of appropriate officials. While the University is authorized to revise the current protection procedures outlined below as deemed necessary, any such procedures must ensure that individuals who do come forward in good faith will be protected by the University from intimidation, harassment, discrimination or other retaliation of any form, including retaliation in employment practices. In addition, the protection procedures established by the University must identify the trustees, officers, employees or outside parties to whom information on possible illegal or fraudulent practices or violations of University policy can be reported.
Current Protection Procedures
The following is a description of current protection procedures developed and implemented by the University as authorized above:
- Fiscal Compliance Hotline
In an effort to provide individuals with a means of reporting irregularities involving financial or accounting matters, the University has implemented a “Fiscal Compliance Hotline” operated by an independent third party. Instructions on how to use Colgate’s Fiscal Compliance Hotline are located on the Colgate website at www.colgate.edu/fiscalcompliancehotline.
- Other Compliance Matters
For concerns about illegal or fraudulent practices or violations of University policy not involving financial or accounting matters, individuals may file a complaint with the Special Assistant to the President for Legal Affairs or the Vice President for Finance & Administration.
The University will protect any individual who submits a report in good faith through one of the aforementioned procedures from intimidation, harassment, discrimination or other retaliation of any form, including retaliation in employment practices. Without limiting the preceding sentence, the University will not discharge, demote, suspend, threaten, or retaliate in any manner against such an individual based upon the actions of such individual with respect to his or her good faith reporting, or participation in the investigation of any reported complaints.
Procedures for Protecting Confidentiality
An individual who comes forward in good faith to report possible illegal or fraudulent practices or violations of University policy through the procedures adopted by the University may request that the report be handled on a confidential basis. While confidentiality cannot be guaranteed, reasonable steps to protect confidentiality, when requested, will be taken to the extent consistent with the need to conduct an adequate investigation and review. Individuals may also submit reports on an anonymous basis. It should be noted, however, that although Colgate endeavors to investigate all reports, including anonymous reports, the nature of anonymous reports makes investigation more difficult and, at times, impossible. As a result, individuals are encouraged to provide their names and contact information.
Reporting to the Board of Trustees
The Special Assistant to the President for Legal Affairs is designated as the administrator of this Whistleblower Policy. As the administrator, he or she shall report to the Audit Committee of the Board of Trustees any instance of alleged intimidation, harassment, discrimination or other retaliation in violation of this Policy, and shall report at least annually to the Audit Committee on matters pertaining to the Policy, including whether any material change has been made to the procedures outlined above.