Whistleblower Policy

Introduction

Smith College employees are expected to adhere to high standards of professional and ethical conduct in carrying out their duties. Maintaining ethical standards, including appropriate accounting, internal controls, auditing and compliance, is the responsibility of every member of the Smith community. Early identification and resolution of ethical issues that might arise are critical to maintaining sound business, including but not limited to financial, practices. This policy sets forth the procedures for reporting and investigating misconduct related to financial and accounting issues, and identifies points of contact to report any other misconduct. Students are directed to use the other means available to them for reporting wrongdoing at the college, including the Dean of Students Office.

Policy

Reporting financial misconduct

At Smith College responsibilities and decision-making are distributed throughout the organization. While we trust our employees to understand and abide by policies and the law, there are, unfortunately, rare instances of improper, even illegal activity. Any employee who observes, first-hand, financial activities or practices that they believe to be against a law or regulation with which the college must comply, or against college policy, should report these activities to the Controller. Employees may also submit concerns confidentially and anonymously regarding accounting, internal controls, auditing and compliance matters to the chair of the Audit Committee of the Board of Trustees by contacting the Board of Trustees’ Office. Employees may also report concerns through EthicsPoint, a third-party provider through which employees may anonymously report misconduct. Care will be taken to maintain appropriate confidentiality throughout the investigatory phase and for as long as possible.

Alternative Reporting of Financial Misconduct

The college intends to monitor all employees’ adherence to financial policies. To this end, alternative mechanisms have been established for bringing forward allegations against the key individuals responsible for carrying out this policy. Information regarding actions of the Controller should be reported directly to the Vice President for Finance and Administration. Information regarding actions of the Vice President for Finance and Administration should be reported directly to the President. Information regarding actions of the President should be reported to the Vice President for Finance and Administration or the Controller, either of whom may consult with the Board of Trustees.

Investigation and Results

The Controller is responsible for investigating specific allegations reported to them. The Audit Committee is responsible for investigating allegations or concerns reported to it. The results of any investigation will be reported to the Vice President for Finance and Administration and the President and, when necessary, to the chair of the Audit Committee of the Board of Trustees. Appropriate action, commensurate with findings, will be taken by the college.

Reporting Other Misconduct

All employees are encouraged to report suspected violations of law or college policy directly to their supervisor. Alternatively, the employee may raise the issue with the department chair, dean, director or other college official/office having responsibility for overseeing compliance with the particular policy or procedure in accordance with the guidance below. Complaints can also be made anonymously via EthicsPoint.

Human Resources: employment policies

Provost/Dean of the Faculty: academic misconduct, code of faculty governance, policy on appointment, reappointment, promotion and tenure

Office of Equity and Inclusion: Discrimination or harassment against students and employees on the basis of race, color, creed, religion, national/ethnic origin, sex, sexual orientation, age, or disability; sexual misconduct

Campus Safety: criminal matters, physical danger

Information Technology Services: Acceptable Use Policy; data security issues

Good Faith

The College will take steps to ensure that employees who come forward in good faith to report any misconduct under this policy will be protected from adverse employment action in retaliation for their reporting. This protection is afforded to all employees who communicate information in good faith and through appropriate channels.

False Reporting

A report made under this policy can have considerable impact on the personal and professional lives of those charged, both during the investigation and in the long term. An employee shall not intentionally misuse the college’s Whistleblower Policy and procedures. Intentional misuse includes, but is not limited to, frivolous claims, attempts to treat a personal grievance or personnel dispute as an allegation of wrongdoing, lack of good faith in invoking the policy or any known false, malicious or misleading statements made at any time under the procedures of the policy. The Controller (when involved) will report to the Associate Vice President for Human Resources, the Director of the applicable office of the employee, and the President, the identity of any employee who is believed to have intentionally misused the Whistleblower Policy. After appropriate review by these individuals, the employee is subject to discipline up to and including termination.

Related Policies

Employment Policies

The Employee Handbook acquaints you with the employment policies and benefits for exempt/administrative staff, nonexempt/administrative support staff and members of the faculty in their status as employees of Smith College. These policies work in conjunction with, and do not replace or amend provisions in, the Faculty Code and Policies or any collective bargaining agreement Smith College has with a union. For additional information about employment with Smith, faculty should consult the Faculty Code and Policies on the Office of the Provost/Dean of the Faculty website, and union employees should consult the terms of their collective bargaining contract. The college reserves the right to make, from time to time, changes in policies and employee benefits that it considers to be in the best interest of the Smith community.

Code of Faculty Governance

The governance of Smith College is an enterprise shared among the Board of Trustees, the faculty, the administration, the students and the staff of the college. As an integral part of that shared governance, the rights and responsibilities of the faculty as granted by the Board of Trustees are described in this Code of Faculty Governance, in the Policy of Appointment, Reappointment Promotion and Tenure, and in the Rules of the Faculty. Moreover, the Board recognizes that the right of academic freedom, as it is set out in the Statement of Academic Freedom and Freedom of Expression, is critical to the educational mission of the college.

Policy on Appointment, Reappointment, Promotion and Tenure

All specific procedures for evaluation are governed by the overall purposes of these regulations, which are threefold: to provide a system for making informed, fair decisions; to assist new colleagues in developing their abilities; and to protect faculty from excessive scrutiny, abusive, or arbitrary treatment and disruption of their teaching.

Notice of Nondiscrimination

Smith College is committed to maintaining a diverse community in an atmosphere of mutual respect and appreciation of differences.

Controller’s Office

The controller’s office accounts for, reports on and safeguards Smith College’s financial resources in a manner that supports the college’s mission and community.

Title IX

Smith College is committed to meeting its obligations under Title IX and maintaining an environment that is free of sex discrimination, including harassment. Such conduct is detrimental to the well-being of our community.

Campus Safety

Through an equitable and inclusive model of service and outreach, the Smith College Campus Safety Department helps ensure that every member of the Smith community can safely learn, live and work on campus in an environment of mutual respect and support. The Campus Safety Department commits to ongoing training and education on a range of topics, such as de-escalation, antiracism and community engagement, that are central to building trust and partnership with students, faculty and staff across campus.

Policy on Acceptable Use of Computer and Electronic Resources

Smith College requires that any person who uses its information technology resources and services must do so in a responsible and ethical manner, abiding by all applicable laws, regulations and policies.

Other Resources

EthicsPoint, a third-party provider, is available for employees to anonymously report misconduct.