Whistleblower Policy

Lesley University is committed to the highest standards of conduct and compliance with all applicable laws. This policy encourages all members of the Lesley University community to report, without fear of reprisal, any concerns relating to the university's financial matters, or violations of any law or university policy.

This policy applies to all members of the Lesley University community, including faculty, adjunct faculty, staff, students, alumni/ae, trustees, vendors, contractors, consultants, guests, and visitors.

I. Reporting Responsibility

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:

  • Fraud, dishonesty, or deception regarding accounting, financial controls, financial reporting, audit, tax matters, and other financial 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

    Make notifications about concerns to any of these people:

    • An employee’s immediate supervisor

    • Marylou Batt, Vice President of Administration, 617-349-8564, marylou.batt@lesley.edu

    • Shirin Philipp, General Counsel, 617-349-8505, legal@lesley.edu; or

    • 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

     

    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.

    Include any supporting documentation in the notification. Notification may be made anonymously.

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 made in bad faith will be considered a serious disciplinary offense and the reporter may be subject to disciplinary action and legal claims.

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. 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, 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.

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).

It is also a violation to retaliate, or threaten to retaliate, against someone 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 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.

Policy History

Adopted by the Board of Trustees: October 4, 2012

Amended by the Audit Committee: May 29, 2013

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.

Questions?
Please contact the administration below with any questions.