Whistleblower Policy

I. Notification
 
Reporting Responsibility. All members of the University community (faculty, adjunct faculty, staff, students, trustees, vendors, contractors, consultants, guests, and visitors) are encouraged to report any concerns relating to the University’s financial matters or violations of any law or University policy. The University’s employees must notify the University with any concerns relating to the University’s financial matters or violations of any law or University policy.
Examples include:
• fraud, dishonesty, or deception regarding accounting, financial controls, financial reporting, audit, and other financial matters
• fraud, dishonesty, or deception regarding tax matters
• unauthorized alteration or manipulation of personal or University data
• pursuit of personal financial gain at the expense of the University
• misappropriation or misuse of University resources
• authorizing or receiving compensation for goods not received or services not performed
• violations of law or regulation such as laws protecting minors or disabled persons
• violations of University policies such as the Acceptable Use Policy
The University also expects its employees to notify the University of any violation of this Whistleblower Policy.
 
Whom to Notify
Notification can be made to any of the following persons:
• An employee’s immediate supervisor
• Marylou Batt, Vice President of Administration, 617-349-8564, mbatt@lesley.edu
• Selase Williams, Provost, 617-349-8587, williams@lesley.edu
• Shirin Philipp, General Counsel, 617-349-8505, legal@lesley.edu
• The Chair of the University’s Audit Committee of the Board of Trustees, who is currently Michael E. Mooney, 617 439 2342, MMooney@nutter.com
Notifications may also be made anonymously at this website:
https://intranet.lesley.edu/quality-of-life/feedback-submission-form/
 
All notifications must then be presented to Shirin Philipp, as General Counsel, unless the notification concerns Ms. Philipp or the General Counsel’s office, in which case the notification must be presented to Marylou Batt, as Vice President of Administration. If the notification concerns both Ms. Philipp and Ms. Batt, the notification must be presented to the Chair of the University’s Audit Committee. The investigation shall be conducted as set forth below.
 
Form of Notice. The notification should specify in reasonable detail the nature of the concern and the persons involved in and with knowledge of the financial matter or violation. Notification should be made in writing so as to promote a clear understanding of the issues raised, but also may be made orally. It should be accompanied by any available supporting documentation. Notification may be made anonymously.
 
II. Acting in Good Faith
Anyone submitting a notification concerning the University’s financial matters or violations of any law or University policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. A reporting person need not be certain that a violation has occurred. Any allegations that are made in bad faith will be viewed as a serious disciplinary offense and the reporter may be subject to disciplinary action and legal claims.
IV. Investigation
The General Counsel (or the Vice President of Administration or the Chair of the Audit Committee) will promptly investigate or delegate investigation of reports of violations and all individuals involved are required to cooperate with such investigations. To the extent practical and appropriate under the circumstances, the identity of anyone who submits a notification or who participates in a resulting investigation will not be disclosed. However, confidentiality cannot be guaranteed.
Depending on the nature of the reported violations or the results of the investigations, matters may be reported to the President’s Cabinet, the Audit Committee, or the Board of Trustees.
Notifications about matters that are covered by other policies and procedures of the University such as (by way of example only) the Conflict of Interest Policy, the Discrimination, Harassment, Sexual Harassment, and Sexual Violence Policy, or the Faculty Grievance Procedure, will be addressed in accordance with the procedures set forth in those other policies or procedures.
 
III. No Retaliation
It is a serious violation of law (with possible criminal penalties) and of this policy to retaliate or threaten retaliation in any form against an individual who in good faith reports a concern about the University’s financial matters or a suspected violation of law or University policy (even if the report is mistaken) or who assists in the investigation of a reported violation. Examples of prohibited retaliation include:
• termination
• demotion
• suspension
• harassment
• failure to consider for promotion
• any other negative action, made directly or indirectly, against a reporting person
Such acts will result in appropriate disciplinary action up to and including termination of employment or dismissal from the University. Anyone who experiences or has knowledge of such retaliatory actions must provide notice immediately pursuant to the procedures described above.
 
IV. No Contract; Amendments
This policy does not create any contractual right or obligation between the University and any employee or other person. The University reserves the right to amend this policy at any time.
Adopted by the Board of Trustees: October 4, 2012
Amended by the Audit Committee: May 29, 2013