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not be used for commercial purposes or by individuals or entities in a manner that implies

College endorsement or responsibility for particular activities, products, or publications, or

by any individual or group promoting itself, without the express written permission of the

Director for Public Relations or designee.

Appendix

vi

Whistleblower Policy

Introduction

A whistleblower policy extends beyond the law, by encouraging reporting of law violations

and suspicions of irregularities as well as prohibiting recrimination and retaliation to those

who report such occurrences or suspicions or those involved in the related investigations.

Bluefield College intends to adhere to all laws and regulations that apply to the College.

Such laws and regulations strengthen and promote ethical practices and ethical treatment

of members of the College community and those who conduct business with the College.

The underlying purpose of this

Whistleblower Policy

is to support the College’s goal of

legal compliance with these laws and regulations and requires the support of all College

employees to achieve compliance. Employees and others are encouraged to use the guidance

provided by this policy for reporting all allegations of suspected improper activities.

Bluefield College also recognizes the necessity of strong internal controls to protect the

financial affairs of the College and help ensure compliance with laws and regulations.

Therefore, financial affairs documentation of the College includes an

Internal Control

Policy Statement

(available for review from the President, Vice President for Finance and

Administration, or Human Resources Director).

Guidelines

The following guidelines should be considered in identifying the possibility of irregularities

to be reported in accordance with this

Whistleblower Policy

:

1) The matter is the result of a significant internal control or policy deficiency;

2) The matter is likely to receive media or other public attention;

3) The matter involves the misuse of College resources or creates exposure to a

liability in potentially significant amounts;

4) The matter involves allegations or events that have a significant possibility of

being the result of a criminal act (e.g., disappearance of cash);

5) The matter involves a significant threat to the health and safety of employees and/

or the public; or

6) The matter is judged to be significant or sensitive for other reasons.

Policy

If any College employee reasonably believes that some policy, practice, or activity of

Bluefield College, or of another employee on behalf of the College, is in violation of law,

the employee immediately should contact the President, Vice President for Finance and

Administration, Human Resources Director, Chair of the Finance Committee of the Board

of Trustees, or Chair of the Board of Trustees, preferably in writing, so as to assure a clear

understanding of the issues raised. The employee should be as specific as possible in

describing the occurrence or suspicion of irregularity, and the description should be factual

rather than speculative or conclusive. The employee in this case is commonly referred to

as a whistleblower. The whistleblower is not an investigator or finder of fact, nor does