Board of Trustees Policy
Date: January 2012
Supersedes: January 2006
The purpose of this policy is to deter and detect fraud or other illegal or unethical activity by establishing a confidential channel of communication by which employees can report activity that they reasonably consider to be illegal, dishonest or in violation of College policies.
A whistleblower as defined for purposes of this policy is an employee of Montgomery County Community College who reports an activity that he or she reasonably considers to be illegal, dishonest or in violation of College policies to one or more of the parties specified in this Policy. The whistleblower is not responsible for investigating the reported activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.
If an employee has knowledge of or a concern about what might be considered illegal or dishonest and fraudulent activity, the employee is to contact his or her immediate supervisor, the Executive Director of Human Resources or the Director of Equity and Diversity Initiatives. The employee must exercise sound judgment to avoid baseless allegations. An employee who files a report in bad faith or intentionally files a false report of wrongdoing will be subject to discipline.
Whistleblower protections are provided in two important areas: confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, a whistleblower’s identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. The College will not retaliate against a whistleblower acting in good faith. Any whistleblower who believes he or she is being retaliated against must contact the Executive Director of Human Resources or the Director of Equity and Diversity Initiatives immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged, investigated and verified.
Three options for reporting suspected illegal or dishonest activity are available. Employees wishing to anonymously report suspicious activity may leave a message on a "Whistleblower Hotline" by calling 215-619-7339 or email firstname.lastname@example.org. Employees may also report suspected illegal or dishonest activity to their supervisor, Human Resources or Internal Audits.
All reports of perceived illegal or dishonest activities will be promptly forwarded to the President, or her designee, who is responsible for coordinating the investigation and any required corrective actions. Employees with any questions regarding this policy should contact the Executive Director of Human Resources or the Director of Equity and Diversity Initiatives.