Whistleblower Protection Policy

A whistleblower, as defined by this policy, is an employee of Eastern Mennonite University who reports an activity of an employee or agent of the university that he/she considers to be illegal or dishonest. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures. Appropriate management officials are charged with these responsibilities.

Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; fraudulent financial reporting; forgery, and other related illegal acts.

If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity by an employee or agent of the university, the employee must contact the vice president for finance. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally or recklessly files a false report of wrongdoing is not a whistleblower and is subject to discipline up to and including termination.

Whistleblower protections are provided in two important areas -- confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower is maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. Eastern Mennonite University will not retaliate against a whistleblower. Any whistleblower who believes he/she is being retaliated against must contact the vice president for finance immediately.

All reports of illegal and dishonest activities by an employee or agent of the university must be promptly submitted to the vice president for finance who is responsible for investigating and coordinating corrective action. Employees with any questions regarding this policy should contact the vice president for finance.

In the event the vice president for finance is suspected to be involved in any illegal or dishonest act or to have not taken appropriate action to investigate or take appropriate corrective action, employees must contact the president of the university.

The Board of Trustee’s Finance, and Audit Committee chair or the Chair of the Board of Trustees should be contacted in the event the suspected illegal or dishonest act involves the university president.

Approved by Board of Trustees, November, 2005