E1.2 Whistleblower

Effective Date: August 30, 2019
Last Reviewed: August 30, 2019

The following policy applies to the receipt, retention, and treatment of complaints regarding Stonehill’s accounting practices and ethics violations. The College strives to protect the confidential, anonymous reporting of employee concerns.

It is the policy of Stonehill College to treat complaints about ethics violations and accounting complaints (i.e., accounting, internal accounting controls, fraud, auditing matters, or questionable financial practices) seriously and expeditiously.

Employees who are concerned or suspect that there has been a violation of Stonehill College’s financial policies, Code of Ethics, or Personal Conduct policies as identified in the Code of Ethics are strongly encouraged to first speak with their supervisor or a representative from the Executive Division, including the President, General Counsel, or Director of Human Resources. Employees who are uncomfortable talking to any of these individuals for any reason should call the ethics hotline established by Stonehill College. The current hotline number is 1-877-472- 2110. The hotline number for Spanish speaking individuals in North America is 1-800-216- 1288. The hotline number shall be maintained by the Vice President for Finance and Treasurer and may be changed from time to time. If the number is changed, the College shall take reasonable steps to inform employees of the change.

The Hotline is available 24 hours a day, 7 days a week. The caller can choose to remain anonymous. If an individual calls the hotline, a trained specialist, who is employed by an outside firm, will listen to the concerns and take notes to prepare a report. The report will be forwarded based on the complaint topic. For example, Human Resource issues will be directed to the Director of Human Resources and General Counsel, in addition to all reports being forwarded to the Vice President for Finance and Treasurer. In cases involving senior leadership, reports will be forwarded to the President of the College. In cases involving auditing, accounting or internal controls issues, or the President, reports will be directed to the Chairman of the Audit Committee of the Board of Trustees.

If requested by the employee, Stonehill College will protect the confidentiality and anonymity of the employee to the fullest extent possible, consistent with the need to conduct an adequate review. Vendors, customers, business partners, and other parties external to the College will also be given the opportunity to submit complaints; however, the College is not obligated to keep complaints from non-employees confidential or to maintain the anonymity of non-employees.

Stonehill College will not retaliate against employees who submit good faith complaints under this Policy.

Access to Reports and Records and Disclosure of Investigation Results:

All reports and records associated with ethics and accounting complaints are considered confidential information and access will be restricted to Officers of the College (or designated2 persons investigating a complaint), members of the Audit Committee, and (if necessary) outside legal counsel. Access to reports and records may be granted to other parties at the discretion of the Audit Committee.

Complaints and any resulting investigations, reports, or actions will generally not be disclosed to the public except as required by applicable legal requirements or regulations.

Retention of Records:

All documents relating to an ethics or accounting complaint made through the process outlined above shall be retained consistent with College document retention policies, for a period of no less than 2 years from the date of the complaint unless otherwise subject to a specified retention period (i.e., accounting records are retained for 7 years), after which the information may be destroyed unless the information may be relevant to any pending or potential litigation, inquiry, or investigation, in which case the information may not be destroyed and must be retained for the duration of that litigation, inquiry, or investigation and thereafter as necessary.