Confidential Complaints about Compliance and Ethics
The following policy and procedures have been adopted by the Board of Trustees’ Audit Committee of Wheaton College, relating to the receipt, retention, and treatment of complaints regards Wheaton’s accounting practices and ethics violations, to protect the confidential, anonymous reporting of employees’ concerns.
Policy and Procedures
It is the policy of Wheaton College to treat complaints about ethics violations and accounting complaints (i.e. accounting, internal accounting controls, fraud, auditing matters, or questionable financial practices) seriously and expeditiously.
If an employee has a concern or suspects there has been a violation of the Wheaton College policies identified in the Ethics Code (see staff handbook), the employee is strongly encouraged to first speak with his or her supervisor or a representative from Human Resources. If the employee is uncomfortable talking to any of these individuals for any reason, Wheaton College has established a compliance hotline and reports can be made by:
- English speaking USA and Canada: 855-840-0070 (not available from Mexico)
- Spanish speaking North America: 800-216-1288 (from Mexico user must dial 001-800-216-1288)
E-mail: firstname.lastname@example.org (must include college’s name – Wheaton College, MA – with report)
Fax: 215-689-3885 (must include college’s name – Wheaton College, MA – with report)
The compliance hotline is available 24 hours a day, 7 days a week. Those reporting through the hotline will have the ability to remain anonymous if they choose. If you call the hotline, a trained specialist, who is employed by Lighthouse, will listen to your concerns and prepare a report. Regardless of the format of submission (phone, web, e-mail or fax), all reports are shared with the Vice President for Finance and Administration, the Chair of the Audit Committee of the Board of Trustees and the Director of the Boston Consortium Shared Internal Audit Group. In addition, reports that involve accounting or auditing issues are routed to the Controller and human resources related issues are also routed to the Assistant Vice President and Director of Human Resources.
Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided. If requested by the employee, Wheaton College will protect the confidentiality and anonymity of the employee to the fullest extent possible, consistent with the need to conduct an adequate review. Vendors, customers, business partners and other parties external to Wheaton College will also be given the opportunity to submit complaints; however, Wheaton College is not obligated to keep complaints from non-employees confidential or maintain the anonymity of non-employees.
Wheaton College will not retaliate against employees for submitting complaints under these procedures.
Access to Reports and Records and Disclosure of Investigation Results
All reports and records associated with ethics and accounting complaints are considered confidential information and access will be restricted to Officers of the college (or a designated person investigating the complaint), members of the Audit Committee, and (if necessary) outside legal counsel. Access to reports and records may be granted to other parties at the discretion of the Audit Committee.
Complaints and any resulting investigations, reports or resulting actions will generally not be disclosed to the public except as required by any legal requirements or regulations.
Retention of Records
All documents relating to an ethics or accounting complaint made through the procedures outlined above shall be retained for a period of no less than 2 years from the date of the complaint unless otherwise subject to a specified retention period (i.e. accounting records are retained for 7 years) after which the information may be destroyed unless the information may be relevant to any pending or potential litigation, inquiry, or investigation, in which case, the information may not be destroyed and must be retained for the duration of that litigation, inquire, or investigation and thereafter as necessary.