Whistleblower Policy

General

Limestone University (the University) expects its employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees of the University must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.

In order to protect employees from repercussions for making good faith disclosures of Improper Activities (see definition below), the University has implemented a Whistleblower Policy. The objectives of the Limestone University Whistleblower Policy are to establish policies and procedures for:

• The submission of concerns regarding Improper Activities by employees on a confidential and anonymous basis.
• The receipt, retention, and treatment of complaints received by the University
• The protection of employees reporting concerns from retaliatory actions.

Improper Activities

Each employee of Limestone University has an obligation to report in accordance with this Whistleblower Policy:

1. a violation of any state or federal law or regulation, including, but not limited to corruption, malfeasance, bribery, theft of University property, fraudulent claims, fraud, coercion, conversion, malicious prosecution, misuse of University property, or willful omission to perform duty or
2. activities that are economically wasteful, or that involve gross misconduct, incompetency, or inefficiency. These actions are collectively referred to as Improper Activities.

Authority of the Provost

All reported Improper Activities will be forwarded to the Provost in accordance with the procedures set forth herein. The Provost shall be responsible for investigating, and making appropriate recommendations to the President with respect to all reported Improper Activities. If the Provost is a subject of the Improper Activities allegations then the report should be made to the University President.

No Retaliation

The Whistleblower Policy is intended to encourage and enable employees to report Improper Activities within the University for investigation and appropriate action. With this goal in mind, no employee who, in good faith, reports an improper Activity shall be subject to retaliation or adverse employment consequences. Moreover, an employee who retaliates against someone who has reported an Improper Activity in good faith is subject to discipline up to and including termination of employment.

Acting in Good Faith

Anyone reporting an Improper Activity must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation of law, involves gross misconduct, incompetency, or inefficiency. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense, and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.

Reporting Concerns

Employees

Employees should first discuss their concern about an Improper Activity with their immediate supervisor. If the individual is uncomfortable speaking with his or her supervisor, or the supervisor is a subject of the Improper Activity, the individual should report his or her concern directly to the Provost. It is the responsibility of the supervisor, upon receiving notification of an Improper Activity, to document the facts as presented and communicate the Improper Activities Report to the Provost.

If the Improper Activity was reported verbally to the Provost, the reporting individual, with assistance from the Provost, shall prepare a written report of the Improper activity. If the Provost, for any reason, does not promptly forward the Improper Activity Report to the President the reporting individual should directly report the concern to the president. Reports of Improper Activities may also be submitted anonymously. Such anonymous concerns should be in writing and sent directly to the Provost.

Handling of Reported Violations

The Provost shall ensure that all reported Improper Activities are addressed in a timely manner. The Provost will notify the sender and acknowledge receipt of the Improper Activity Report within five business days, if possible. It will not be possible to acknowledge receipt of anonymously submitted concerns.

All reports will be promptly investigated by the Provost, and appropriate corrective action will be recommended to the President if warranted by the investigation. In addition, action taken must include a conclusion and/or follow-up with the complainant for complete closure of the concern.

Copies of all reports received under the Whistleblower Policy and all documents relevant to the investigation and resolution of these reports will be permanently filed in the office of the Provost.

Confidentiality

Reports of Improper Activities, and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Disclosure of reports of Improper Activities to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. Such conduct may also give rise to other actions, including civil lawsuits.