Financial Integrity Policy

Ohio Wesleyan University (the University) is committed to lawful and ethical behavior in all of its activities and requires Trustees, officers, faculty, staff, students and volunteers to act in accordance with all applicable laws, regulations and policies and to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.

The objectives of the University’s Financial Integrity Policy are to establish policies and procedures to:

• prevent or detect and correct improper activities
• encourage each University Trustee, officer, employee and volunteer (Reporting Individual) to report what he or she in good faith believes to be a material violation of law or policy or questionable accounting or auditing matter by the University
• ensure the receipt, documentation, retention of records, and resolution of reports received under this policy
• protect Reporting Individuals from retaliatory action.

Reporting Responsibility

Each reporting individual has an obligation to report what he or she believes is a material violation of law or policy or any questionable accounting or auditing matter by the University, its officers, Trustees, employees, volunteers, agents or other representatives. Reporters must also notify the University if an action needs to be taken in order for the University to be in compliance with law or policy or with generally accepted accounting practices. The types of concerns that should be reported include, for the purpose of illustration and without being limited to, the following:

• providing false or misleading information on the University’s financial documents, grant reports, tax returns or other public documents;
• providing false information to or withholding material information from the University’s auditors, accountants, lawyers, Trustees or other representatives responsible for ensuring University compliance with fiscal and legal responsibilities;
• material violations of University policy, including among others, confidentiality, conflict of interest, whistleblower, ethics and document retention;
• facilitation or concealing any of the above or similar actions
• embezzlement, private benefit, or misappropriation of funds;

Reporting Concerns

Employees

Whenever possible, an employee should seek to resolve concerns by reporting issues directly to his/her manager or to the next level of management as needed until matters are satisfactorily resolved. However, if for any reason an employee is not comfortable speaking to a manager or does not believe the issue is being properly addressed, the employee may contact the Director of Human Resources, the University Vice President associated with his/her area, or the President. Whenever practical, reports should be in writing.

Trustees and Other Volunteers

Trustees and other volunteers may submit concerns to the President or directly to the Chair of the Audit Committee or to the Chair of the Board.

Handling of Reported Violations

The University will investigate all reports filed in accordance with this and any other applicable policies with due care and promptness. University staff will issue a full report of all matters raised under this policy to the appropriate authority. The President will share results of these investigations to the Audit Committee.

No Retaliation

This Whistleblower Policy is intended to encourage and enable Trustees, volunteers, and employees to raise serious concerns within the organization for investigation and appropriate action. With this goal in mind, no Trustee, volunteer, or employee who, in good faith, reports a concern shall be threatened, discriminated against or otherwise subject to retaliation or, in the case of an employee, adverse employment consequences as a result of such report. Moreover, a volunteer or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.

Acting in Good Faith

Anyone reporting a concern must act in good faith and have reasonable grounds for believing the matter raised is a serious violation of law or policy or a material accounting or auditing matter. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, with gross negligence, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal from the volunteer position or termination of employment. Depending on the circumstances, such conduct may also give rise to other actions, including civil or criminal lawsuits.

Confidentiality

Reports of concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible. However, consistent with the need to conduct an adequate investigation, the University cannot guarantee complete confidentiality. Disclosure of information relating to an investigation under this policy by University staff, Trustees, or others involved with the investigation of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and, with respect to University employees, may result in discipline, up to and including termination of employment. Depending on the circumstances, such conduct may also give rise to other actions, including civil or criminal lawsuits.

Campus Conduct Hotline

OWU has made a hotline available for anonymously disclosing evidence of unlawful or unethical practices. Use this hotline to report unsafe or unethical behavior.

The campus conduct hotline is available to call toll-free, 24 hours a day, 7 days a week: 1-866-943-5787

Information disclosed on this hotline is anonymous, as the number is designed to protect employees and students from retaliation.

Campus conduct topics that are appropriate for reporting through this hotline:

• ADA Rules Violation
• Discrimination
• Faculty/Staff Handbook Violation
• Fraudulent Accounting or Bookkeeping
• Harassment – Not Sexual
• Hate Messages
• Hostile Workplace
• Illegal or Unethical Business Practices
• NCAA/NAIA/NJCAA Rules Violation
• Retaliation
• Safety and Security
• Waste of Institution Resources
• Wrongful Termination
• Bullying
• Student Handbook Violation
• Sexual Harassment / Assault
• Other