Purpose of the Whistleblower Policy
Colgate University (“the University”) is committed to appropriately protecting its physical, financial and human resources, to complying with all applicable laws and regulations, and to maintaining high ethical standards. The University requires 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. All employees are expected to be honest and ethical in their dealings with other employees and with University business partners. Even the appearance of misconduct or impropriety can be damaging to the University, and therefore the University also expects that all employees will report any observed actual or suspected violations of law or policy or Colgate’s high ethical standards, and that all employees will cooperate with any investigation required by such reports. This Whistleblower Policy is designed to further that objective.
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.
Protection from Retaliation
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. Any protection procedures established by the University will 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:
- Direct Report
For concerns regarding illegal or fraudulent practices or violations of University policy individuals may file a complaint with the senior advisor to the president; assistant dean for administrative advising (Christopher Wells) or the senior vice president for finance & administration and chief investment officer (J.S. Hope).
- Whistleblower Hotline
In an effort to provide individuals with additional options for reporting irregularities with added protection for confidentiality, the University has implemented a “Whistleblower Compliance Hotline” operated by an independent third party.
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 senior advisor to the president; assistant dean for administrative advising, Christopher Wells, 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.
Colgate is deeply committed to maintaining high standards for ethical behavior for its employees, to ensuring compliance with all applicable laws and regulations, and to appropriately protecting its financial resources. The university has a longstanding policy that encourages employees to report concerns about unethical or illegal conduct in the workplace to their supervisor or a representative in the Human Resources office.
The University continues to recommend that employees attempt to resolve matters through established reporting channels whenever possible.
However, in an effort to provide employees with an additional means of reporting improprieties, Colgate has implemented a whistleblower hotline.
In order to protect the identity of employees reporting a concern while ensuring that the university appropriately investigates and resolves any identified issues, Colgate has contracted with an independent third-party, Compliance Concepts Inc. Colgate’s hotline allows callers to confidentially report concerns regarding inappropriate activity or behavior.
All calls submitted through the hotline will be given careful attention with the objective of responding to and correcting the reported situation; employees making a good faith report through this system will be protected by the University’s Whistleblower Policy.
The hotline is not a substitute for, and does not supersede, any existing university protocols for reporting concerns regarding discrimination, harassment, or inappropriate employee workplace conduct. It should not to be used to report health, fire and safety, or personnel concerns; student behavioral issues; or matters related to academic dishonesty.
Instructions for Using the Hotline
- Dial 1-800-910-6717
- Call is received by an operator from Compliance Concepts
- The operator will ask whether the caller would like to remain anonymous or be identified.
- If the caller elects to be identified, the operator will ask for the caller’s contact information. If the caller wishes to remain anonymous, no contact information will be obtained.
- Information on the concern is gathered and a call report is prepared by the operator
- Call information is repeated and verified to the caller
- A call reference number and a call back date is provided to the caller
- The call report is reviewed by a senior risk analyst at Compliance Concepts.
- The senior risk analyst delivers the report to the appropriate Colgate representative, depending on who the concern is about, for investigation. A call received about a university officer, who would normally field and investigate all concern calls, will be directed to another responsible university representative.
- If the caller has identified himself or herself, a Colgate representative will follow up directly with the caller to provide summary information on the status of the investigation. If a caller asked to remain anonymous, the caller can follow up with Compliance Concepts if he/she wishes to monitor the status of the investigation. This will protect the caller’s anonymity.
Please contact JS Hope, senior vice president for finance and administration and chief investment officer at email@example.com; Thomas O’Neill, associate vice president and controller at firstname.lastname@example.org; or Christopher Wells, senior advisor to the president; assistant dean for administrative advising at email@example.com.