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VII. Policy On Reporting Improper or Unlawful Activities and Prohibition of Retaliation

This policy governs the reporting and investigation of claims of certain types of improper or unlawful activities as defined below and the prohibition of retaliation against individuals reporting such activities. It describes the procedures to be followed for investigation of reports of improper or unlawful activities and for addressing complaints of retaliation for raising such issues. Nothing in this policy statement replaces the existing policies and procedures governing harassment and discrimination, equal opportunity, the handling of employment grievances and other personnel policies detailed in official handbooks and contracts governing employment conditions.

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A. Policy

Vassar College seeks to achieve its mission as an educational institution by conducting its affairs ethically, and in full compliance with all federal, state and local laws. The College acknowledges its responsibility for the stewardship of public and private resources provided in pursuit of that mission. Vassar faculty, administrators, and staff are expected to adhere to high standards of professional and ethical conduct in carrying out their duties. The College’s Governance, policies, management, internal controls and operating procedures are designed to prevent, deter, and, if necessary, detect improper or unlawful activities. To these ends, the College has established the following procedures to investigate, address, and report, as appropriate, claims of improper activities. These procedures include measures to prevent, and if necessary to respond to, any retaliatory action taken against an employee who, in good faith, reports improper activities.

"Improper activities" are defined, for purposes of this policy, as actions or failures to act by the College itself, or by its officers or employees in the course of their duties, which may result in either violations of Federal, State, or local law, or create a danger to public health or safety. The term also includes fraudulent or dishonest conduct by College officers or employees in the course of their duties, such as providing false or misleading information with regard to the College's financial status.

The College prohibits any retaliation against employees who in good faith report improper activities, who participate in an investigation pertaining to alleged improper activity, or who refuse to engage in what they believe in good faith to be illegal activities. A College employee may not use official authority, directly or indirectly, in order to discourage an employee to come forward with a suspected improper activity.

Employees are encouraged to use the procedures outlined below to report improper activities. Alternatively, an employee may choose to report allegations of improper activities to the appropriate government agency or contact the New York State Attorney General’s Office.

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B. Procedures

  1. How to Make a Report. A report of improper activities may be made by any faculty or staff member of the College to the Controller (Vassar College Box 12) or the Director of Equal Opportunity (Vassar College Box 645) or the Faculty Director of Affirmative Action (Vassar College Box 645). Written reports regarding improper activities may also be sent to the President (Vassar College Box 1) or directly to the Board of Trustees, by writing to the Chair of the Audit Committee, in care of the Secretary of the Board (Vassar College Box 720).

  2. Report in Writing. Reports of improper activities should be made in writing for the sake of clarity. Reports should be factual and contain the specific information that is known by the person making the report. If a report of improper activities is made orally to the Controller, the Director of Equal Opportunity, or the Faculty Director of Affirmative Action, the individual receiving the report is then responsible for promptly documenting the details of the oral report in writing and providing a confidential copy to the complainant.

  3. Report Promptly. Reports should be made promptly; the passage of time increases the difficulty of verifying allegations.

  4. Handling of Reports. The party receiving the report of improper activities (normally the Controller, the Director of Equal Opportunity or the Faculty Director of Affirmative Action) will ensure that an investigation appropriate to the allegation, including, if appropriate, the retention of legal counsel, accounting, or other specialists, takes place promptly and thoroughly. The College will treat the information provided with discretion and, to the extent permitted under law, confidentially. There may exist circumstances where the College is required to disclose information it is provided.

  5. Response to Violations. The College will respond with remedial or disciplinary action as appropriate to a finding of improper activities.

  6. Policy of Non-Retaliation. The College has a strict policy prohibiting any retaliatory action against any College employee who reports in good faith improper activities or who refuses to perform actions that an employee in good faith believes would result in a violation of law. Incidents of retaliation should be reported to the Director of Equal Opportunity for issues involving administrators or staff, or to the Faculty Director of Affirmative Action for issues involving faculty, who will investigate and report the findings to the appropriate senior officer. Reports of improper retaliation will be investigated promptly, and disciplinary action will be taken where the report is verified and/or substantiated.

  7. Report to Audit Committee. All investigations and claims of retaliation under this policy will be compiled annually by the Controller, the Director of Equal Opportunity, and the Faculty Director of Affirmative Action and a summary written report will be provided to the Audit Committee of the Board of Trustees.
    (Approved by the Board of Trustees, May 2007.)

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