告密者的政策

Reporting Suspected Misconduct, Dishonesty, or Fraud

OES strives to uphold the highest possible standards of ethical, moral and legal conduct. The School is committed to maintaining a workplace where employees, 军官 and trustees are free to raise concerns in good faith regarding our governance practices. 与这一承诺一致, this policy provides an avenue for employees, 军官 and trustees to report concerns about suspected misconduct, 不诚实, 不符合法律, 或者欺诈,不用担心报复.

This policy and reporting procedure is not intended for reporting of day-to-day matters, 比如学生纪律问题, 就业问题, general complaints or other matters that are regularly handled through other policies and procedures.

范围

The reporting procedure outlined in this policy should be used to report suspected misconduct, 不诚实, 法律不符合, conflict of interest 或欺诈 in the operation of the organization (collectively referred to as "Suspected Violations"), 包括但不限于:

  • Theft or other misappropriation of OES assets
  • Deliberate misstatements, falsification or other irregularities in OES financial reports or records
  • Non-compliance with state or federal laws
  • 滥用OES资源
  • 非法活动
  • 伪造或变造文件
  • 违反州或联邦法律
  • 其他形式的欺诈或渎职行为

过程

报告可疑的违规行为: 员工, 军官 and trustees may report Suspected Violations to the Head of School or to the Chair of the Audit Committee (the "Chair") verbally or in writing. The Chair can be reached via email at: confidential@lawschool.peninsulaedi.com.

匿名报告: 员工, 军官, and trustees are encouraged to disclose their identity when reporting Suspected Violations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. 然而, anonymous reports of Suspected Violations will be treated in the same manner as any other reports. 员工, 官, or trustee may make the anonymous report to the Head of School or to the Chair of the Audit Committee verbally or in writing. The Chair can be reached via email at: confidential@lawschool.peninsulaedi.com.

时间: The earlier a Suspected Violation is reported, the easier it is to take effective action. 员工, 军官 and trustees are therefore encouraged to make a report as soon as they become aware of a Suspected Violation.

调查可疑违规行为: Once a Suspected Violation is reported to the Head of School or to the Chair, the Head of School and Chair will initially assess the matter and recommend further action to the Audit Committee, 如果合适的话, 这可能包括进一步的调查, 纠正措施, 纪律处分, reporting the matter to the proper authorities or other appropriate action. The Audit Committee may enlist Committee members, employees of the school and/or outside legal, 会计或其他顾问, 适当的, 进行调查. Investigations will be handled with sensitivity, discretion and confidentiality to the fullest extent practicable under the circumstances, but complete confidentiality cannot be guaranteed, particularly if it will inhibit a thorough investigation.

If the investigation reveals that wrongdoing has taken place, prompt and effective remedial action will be taken. 这可能包括纪律处分, 终止, legal action or other corrective measures to prevent further violations.

保障措施

没有报复: 一个员工, 官, or trustee who reports a Suspected Violation in good faith shall not suffer any harassment, retaliation or adverse employment consequences for making the report. Any person who participates in the investigation of a Suspected Violation shall not suffer any harassment, retaliation or adverse employment consequences. Any harassment, retaliation or adverse employment consequences should be reported to the 29 Chair. 一个员工, 官 or trustee who retaliates against a person for reporting a Suspected Violation in good faith or for participating in the investigation of a Suspected Violation shall be subject to 纪律处分, up to and including 终止 of employment or other authorized sanction. This policy is intended to encourage and enable employees, 军官 and trustees to report Suspected Violations within the organization prior to seeking resolution outside the organization.

另外, 没有员工, 官 or trustee shall be adversely affected because he or she refuses to carry out a directive which, 事实上, 构成不当行为, 欺骗或欺诈, 或者违反州或联邦法律.

诚信行事: Anyone reporting a Suspected Violation should be acting in good faith and have reasonable grounds for believing the information disclosed indicates misconduct, 不诚实, 违反州或联邦法律, 或欺诈. Making allegations that prove not to be substantiated and that were made maliciously or with the knowledge that they were false will be viewed as a serious offense and will lead to 纪律处分 up to and including 终止.