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the whistleblower determine the appropriate corrective or remedial action that may be

warranted. Whistleblower reports also may be made anonymously.

The President, Vice President for Finance and Administration, Human Resources Director,

Chair of the Finance Committee of the Board of Trustees, and/or Chair of the Board

of Trustees will acquire the services of an external, independent source to perform any

necessary audit/verification work. As is appropriate and/or as guided by legal counsel

if consulted, the College will report suspected or confirmed irregularities to relevant

officials. The College will encourage the performance of sufficient tests and investigations

to identify the weakness in controls or security which contributed to such occurrence and

request recommendations for corrective action as necessary. They will be responsible for

ensuring that recommendations are implemented or that mitigating changes are made. If

the occurrence is deemed to be a violation of the law, the College will participate in any

investigation requested by authorities; and immediate, relevant personnel changes will be

made. In all instances, the College retains the prerogative to determine when circumstances

warrant an investigation and, in conformity with this policy and applicable laws and

regulations, the appropriate investigative process to be used. Those receiving whistleblower

reports always should share the report and results of the investigation with the Finance

Committee of the Board of Trustees. The Finance Committee will use this information

to identify important trends requiring further consideration relative to best practices and

internal controls of the College.

Applicability: Whistleblowers, Participants, and Subjects

All employees of the College have a duty to cooperate with investigations initiated under

this

Whistleblower Policy

. The intentional filing of a false report, whether orally or in

writing, is itself considered an improper activity which the College has the right to act

upon. Regarding a suspected irregularity, whistleblowers may be committing an improper

activity themselves by attempting to obtain evidence for which they do not have a right of

access. Whistleblowers have a responsibility to be candid with those to whom they report

a suspected irregularity and with investigators. They should set forth all know information

regarding reported allegations and be prepared to be interviewed by College investigators.

Whistleblowers must provide sufficient corroborating evidence to the extent possible to

justify commencement of an investigation. However, whistleblowers are not to act on their

own in conducting any investigative activities, nor do they have a right to participate in any

investigative activities other than as requested by investigators. Whistleblowers have a

right to be informed of the disposition of their disclosures, absent overriding legal or public

interest reasons.

College employees who are interviewed, asked to provide information or otherwise

participate in an investigation have a duty to fully cooperate with College-authorized

investigators. Such participating employees should refrain from discussing or disclosing the

investigation or their testimony with anyone not connected to the investigation. In no case

should the participant discuss with the investigation subject the nature of evidence requested

or provided or testimony given to investigators, unless agreed to by the investigator.

The decision to conduct an investigation of the person(s) alleged in a whistleblower report

is not an accusation. The investigation is to be treated as a neutral fact finding process. The

outcome of the investigation may or may not support a conclusion that an improper act was

committed and, if so, by whom. Subjects should normally be informed of the allegations at

the outset of a formal investigation and have opportunities for input during the investigation.

Subjects have a duty to cooperate with investigators to the extent that their cooperation will