Policy

St. Norbert College is committed to lawful and ethical behavior. Thus, the college expects all members of the college community – students, employees, trustees, etc. – to follow its policies and all applicable laws, rules and regulations. In addition, the college encourages all members of the college community to report what they, in good faith, believe or suspect to be violations of college policy, violations of law, dishonesty, fraud or other misconduct. The college is also committed to protecting anyone making such a report (i.e, the whistleblower) from retaliatory action.

Definitions
Wrongful Conduct

A violation of college policy; a violation of applicable state or federal laws; dishonesty; fraud and other forms of misconduct. 

Procedure

A. Reporting
Activities to Report
St. Norbert encourages you to report any suspected wrongful conduct. Examples include:  

1. Stealing, misusing or misappropriating college property, resources or assets
2. Mismanaging or wasting college or college-related funds
3. Improperly destroying records
4. Providing inaccurate, false or misleading information
5. Partaking in unethical activities
6. Creating a substantial and specific danger to public health or safety
7. Violating any law, regulation, rule, policy, etc.
8. Forging or altering documents without authorization
9. Concealing any of the above actions

Reporting Procedure
If you wish to report wrongful conduct, contact an appropriate supervisor as soon as you’re aware of the misconduct. Your supervisor is then expected to immediately forward your report to Human Resources. If, for any reason, you find it difficult to make a report to your supervisor, you may file the report directly with the assistant vice president of human resources. 

To preserve the integrity and effectiveness of an investigation into an allegation of wrongful conduct, please do not discuss the situation with anyone other than the person to whom you made the report and any individuals the college designates during the investigation. Similarly, the supervisor forwarding your report shouldn’t discuss it with anyone else other than personnel designated by the college. One exception: If you’re reporting potential criminal conduct, you may also report it to the appropriate law enforcement officials.

Good-faith Reporting
All reports must be made in good faith, where you have reasonable grounds to believe or suspect someone is or has engaged in wrongful conduct. You aren’t expected to, nor should you, conduct your own investigation prior to making a report. It is a serious offense for anyone to knowingly making false allegations about wrongful conduct, and any such actions may result in discipline, including termination.

B. Investigating
Following the receipt of a report, the college will appoint a trained investigator(s) free from any conflicts of interest. (The college may engage outside legal counsel for these services.) The investigator(s) will conduct a preliminary assessment to determine whether an investigation should be opened, based on the facts provided. Prior to initiating the preliminary assessment or investigation, the college will determine whether or not the matter should involve law enforcement authorities, and whether or not law enforcement authorities should be contacted before proceeding.

If an investigation is deemed appropriate, an internal and/or external investigator(s) will proceed with an investigation. The scope and timing of the investigation will vary by the circumstances, but an investigation will generally involve a review of relevant documents and other records (e.g., physical documents, emails, browser histories, voicemails, text messages, etc.) and interviews with individuals who may have knowledge of the situation.

If the college determines wrongful conduct has occurred after the investigation is completed, a written finding will be presented to the appropriate senior administrator(s) or Board of Trustees for appropriate action. This action will be based, in part, on the nature and scope of the wrongful conduct.

The person who reported the wrongful conduct may be informed of the findings of any investigation and the report’s disposition, including any action taken against an employee as a result. However, there may be reasons not to do so, including legal limitations and confidentiality provisions.

Confidentiality
Reports of suspected wrongful conduct, and any investigations into them, will be kept confidential to the extent possible. However, the college cannot guarantee complete confidentiality in order to conduct an adequate investigation. St. Norbert considers it a serious offense if a college member discloses information related to a wrongful conduct report and investigation to any uninvolved individual(s). Such action may result in discipline, including termination. 

Retaliation
The college takes great care to ensure that whistleblowers acting in good faith do not suffer any adverse employment action or retaliation. Any employee who retaliates against another employee for making a good faith wrongful conduct report, or for participating in an investigation, is subject to discipline, including termination.