Saint Vincent College requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their responsibilities. As employees and representatives of Saint Vincent, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
It is the responsibility of all directors, officers and employees to follow this practice and to report violations or suspected violations in accordance with the Whistleblower Policy. These violations may include any of the published policies of the College, but also include financial improprieties or irregularities. Financial improprieties or irregularities means, among other similar matters, misappropriation of funds, supplies, property, or other resources; misreporting hours worked; fraud or deliberate errors in the preparation, evaluation, review or audit of any financial statement of the College; forgery or alteration of College financial documents or financial computer files; pursuit of financial benefit or advantage in violation of Saint Vincent’s conflict of interest policy; or deficiencies in or noncompliance with Saint Vincent’s financial controls.
No director, officer or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within Saint Vincent prior to seeking resolutions outside of Saint Vincent.
Saint Vincent encourages employees to share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, the employee is not comfortable speaking with his or her supervisor or he or she is not satisfied with their supervisor’s response, employees are encouraged to speak with someone in the Human Resources Office or anyone in management whom the employee is comfortable in approaching. Supervisors and managers are required to report suspected violations to Saint Vincent’s Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when an employee is not satisfied or uncomfortable with discussing his or her concerns with these persons, the individual should contact Saint Vincent’s Compliance Officer directly.
If the complaint or concern is regarding the conduct of the designated Compliance Officer, the President is the appropriate authority to report such a concern. If anonymity is desired, an unsigned written report may be delivered to the Office of the President via internal house mail or via regular US mail. The President or his designee will be responsible to conduct a thorough investigation of the reported violation as outlined above including reporting the matter to the Finance, Audit, and Enrollment Committee of the Board of Directors and work with the Committee until the matter is resolved.
Saint Vincent’s Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations, shall advise the President and/or the audit committee. The Compliance Officer has direct access to the Finance, Audit, and Enrollment Committee of the Board of Directors and is required to report to the audit committee at least annually on compliance activity. Saint Vincent’s Compliance Officer is the Vice President of Finance and Administration.
The Finance, Audit, and Enrollment committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the committee of any such complaint and work with the committee until the matter is resolved.
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously to a designated hotline: 724-805-1900. Reports or violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five (5) business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.