1.3.2 Whistleblower Policy

1.3.2

Whistleblower Policy

New Policy Proposed: July 8, 2015

Effective Date: August 7, 2015

The University is committed to promoting compliance with the laws, rules, and regulations that govern its business operations and encouraging its employees to report unlawful conduct. Below are the procedures by which employees may report complaints or concerns about any fraudulent, illegal or unethical conduct within the University.

Employees are often the first to become aware of unethical behavior or business improprieties, but may not express their concerns for fear of retaliation. The University will not tolerate harassment, retaliation or reprisals of any time against any employee who has, in good faith, protested or raised a complaint against some policy or practice of the University or any of its employees.

I. WHAT CAN BE REPORTED?

This Whistleblower Policy applies to serious concerns relating primarily to unethical, fraudulent or illegal business conduct. This Whistleblower Policy is not intended to address every concern that may arise in the workplace. Employees should be aware that the University has other policies and procedures and available channels of communication for reporting certain concerns that may not be covered by this Whistleblower Policy and/or that may be more appropriate mechanisms for addressing such concerns, including the University’s anti-discrimination and harassment policies.

II. PROCEDURE FOR SUBMITTING CONFIDENTIAL COMPLAINTS

Employees may submit complaints, concerns, and information regarding potential unethical, fraudulent or illegal conduct to their immediate supervisors. However, if the employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor’s response, or if the concern relates to a particularly serious or sensitive issue, including accounting-related matters and allegations of corporate fraud, the employee is encouraged to raise the matter directly with the University’s Internal Auditor, who reports dually to the President and the University System of Georgia, through the University’s Compliance Reporting Hotline which is available 24 hours a day, 7 days a week.

Online at: https://mga.alertline.com/gcs/welcome.

By telephone: 1-877-516-3460

Complaints may be made anonymously. Employees who choose to identify themselves when submitting a report may be contacted by a University representative in order to gain additional information. To the extent permissible under applicable law, the University will keep confidential all communications with a reporting employee relating to that employee’s complaint.

When submitting a complaint, employees should provide as much detailed information as possible, including the background and history of the concern, names, dates and places where possible, and the reasons why the situation is reason for concern. This is particularly important where an employee submits a complaint on an anonymous basis, as the University will be unable to contact the reporting employee with requests for additional information or clarification.

The University will respond to employee concerns by investigating them, if appropriate. Please note that an investigation into concerns raised is not an indication of whether they have been confirmed or rejected. In order to protect individuals and the University, initial inquiries will be made to decide whether an investigation is appropriate and, if so, the form and scope of the investigation. The action taken by the University will depend on the nature and severity of the concern, as determined during any investigation.

Concerns or allegations that fall within the scope of another policy (for example, discrimination and harassment policies), will normally be investigated and remedied consistent with the specific procedure applicable to that policy.

All conversations, calls, and reports made under this policy in good faith will be taken seriously. However, employees who file reports or provide evidence that they know to be false or without a reasonable belief in the truth and accuracy of such information will not be protected by this policy and may be subject to corrective action up to and including immediate termination.

III. POLICY PROHIBITING UNLAWFUL RETALIATION OR DISCRIMINATION

The University recognizes that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal. The University will not tolerate retaliation and will do what it lawfully can to protect employees when they raise a concern in good faith.

It is the University’s policy to adhere to all applicable laws protecting its employees against unlawful discrimination or retaliation as a result of their lawfully reporting complaints or participating in investigations regarding alleged unethical, illegal or fraudulent matters.

In particular, the University prohibits any form of unlawful discrimination or retaliation or taking any adverse action against employees for engaging in the following conduct:

  • Providing information or otherwise assisting in an investigation regarding any conduct that the employee reasonably believes violates federal or state law or regulations; and/or
  • Filing, testifying, participating in, or otherwise assisting in any proceeding relating to an alleged violation of federal or state laws or regulations.

Employees who believe that they have been subjected to any conduct that violates this policy may file a complaint using the procedures outlined above. Any employee who unlawfully discriminates or retaliates against another employee as a result of his or her protected actions as described in this policy may be subject to corrective action, up to and including termination.