Whistle Blower Policy


Purpose and Applicability

The purpose of this policy is to set forth [Institution’s] policy on Board Member, employee, volunteer, student, vendor, alumni and applicant disclosure of misconduct relating to accounting or auditing matters, and to protect Board Members, employees, volunteers, students, vendors, alumnae and applicants from retaliation in the form of an adverse employment and other action for disclosing what the Board Member, employee, volunteer, student, vendor, alumni or applicant believes evidences certain unlawful practices. This policy is applicable to all Board Members, employees, volunteers, students, vendors, and alumnae of Wagner College and to applicants for jobs at Wagner College.

Statement of Policy

It is the policy of the [institution] that Board Members, employees, volunteers, students, vendors, alumnae and applicants shall be free without fear of retaliation to make known allegations of alleged misconduct existing within the [Institution] that he or she reasonably believes constitutes the following: wire fraud, mail fraud, bank fraud, securities fraud or questionable accounting, internal controls, and auditing matters. It is further the policy of the institution that Board Members, employees, volunteers, students, vendors, alumnae and applicants shall be free without fear of retaliation to make known allegations of alleged misconduct existing within the [institution] that he or she reasonably believes constitutes a violation of the [Institution’s] stated policies, procedures or legal obligations.
A Board member, employee, volunteer, student, vendor, alumni or applicant shall not take or refuse to take any employment or other action in retaliation against any individual(s) or organization who discloses information regarding misconduct under this policy or who, following such disclosure, seeks a remedy provided under this policy or any law or other [Institution] policy. Retaliation for disclosures made under this policy may result in suspension, termination, cancellation of the applicable vendor contract, removal from campus or any other action the Institution deems necessary.

Process for Disclosure

An employee, volunteer, student, vendor, alumni, or applicant shall disclose all relevant information regarding evidenced misconduct to the following designated intake officers, in accordance with the subject matter of the disclosure:

Subject Matter

Intake Officer

Disability Violations Joseph Romano, Chief of Staff
Discrimination/Harassment/Retaliation Joseph Romano, Chief of Staff
Environmental Hazards/Unsafe Workplace Condition David Martin, V.P. for Administration
Faculty/Staff Handbook Violation Joseph Romano, Chief of Staff
Financial Improperties/ Fraudulent Accounting (Including but not limited to: wire fraud, mail fraud, bank fraud, securities fraud or questionable accounting, internal controls, and auditing matters) William Mea, V.P. for Finance & Business
Illegal/Unethical Business Practices William Mea, V.P. for Finance & Business
Athletic Rules Violation Angelo Araimo, V.P. Enrollment & Planning
Safety/Security Issues David Martin, V.P. for Administration
Student Handbook Violation Lily McNair, Provost
Wrongful Termination Joseph Romano, Chief of Staff
Other Conduct SPECIFY APPROPRIATE OFFICIAL

If the disclosure is by a Board Member it shall be made to the Chair of the Executive Committee, unless the complaint involves the Chair of the Executive Committee, in which case the complaint shall be made to the Chair of the Board.

Any disclosure shall be made in a signed written document within ninety (90) days of the day on which the complainant knew or should have known of the misconduct.  If the Board Member, employee, volunteer, student, vendor, alumni, or applicant would rather contact a source outside of the institution, he or she may contact CAMPUS CONDUCT HOTLINE at 1-866-943-5787 within ninety (90) days of the day on which the complainant knew or should have known of the misconduct.

  • The intake officer shall consider the disclosure and take whatever action he or she determines to be appropriate under the law and circumstances of the disclosure.
  • In the case of disclosure of misconduct involving the designated intake officer, the disclosure shall be directed to [alternate] or designee.  The [alternate] or designee shall consider the disclosure and take whatever action he or she determines to be appropriate under the law and circumstances of the disclosure.
  • In the case of disclosure of misconduct involving the [alternate] , the disclosure shall be directed to [second alternate, e.g., the Chair of the Board of Trustees].  The [second alternate] shall consider the disclosure and take whatever action he or she determines o be appropriate under the law and the circumstances of the disclosure.
  • In the case of disclosure involving financial misconduct, the intake officer or the CAMPUS CONDUCT HOTLINE shall also provide the disclosure to the Audit Committee for their review and consideration.  The Audit Committee shall have the authority to resolve the matter in accordance with its stated procedure.
  • In the case of disclosure to CAMPUS CONDUNCT HOTLINE that does not involve financial misconduct, the Audit Committee shall be entitled to receive a summary of the disclosure from CAMPUS CONDUCT HOTLINE.  As its discretion, the Audit Committee shall have the authority to resolve the matter in accordance with its stated procedure.
  • If the disclosure involves the President, the disclosure may be directed to the Chair of the Board of Trustees or the Chair of the Executive Committee or his/her designee.
  • If the disclosure involves a member of the Board of Trustees, the disclosure may be directed to the President or Chair of the Board or his/her designee.