D.6. Whistleblower Policy

Policy Statement

Middlebury College has a deep commitment to responsible stewardship of its financial resources and accountability for the public and private support that enables the College to pursue its mission. Middlebury College is committed to compliance with the laws and regulations to which it is subject, and to promulgate College policies and procedures to interpret and apply these laws and regulations in the College setting.

Reason for the Policy

Middlebury College’s internal controls and operating procedures are intended to detect and to prevent or deter improper activities. However, even the best systems of control cannot provide absolute safeguards against irregularities. Middlebury College has a responsibility to investigate and report to appropriate parties’ allegations of suspected improper activities and the actions taken by the College.

Applicability of Policy

It is important for all College employees, students, parents, alumni and other individuals to feel free to report facts which may indicate that a law, regulation or policy has been violated without fear of any form of reprisal or retaliation. To ensure unfettered, good faith reporting it is the policy of the College that no one who, in good faith, reports a suspected violation of law, policy or procedure will suffer any form of retaliation, or any adverse employment, academic or educational consequence on account of such report. It is the intention of the College to take whatever action may be necessary to prevent and/or correct violations of this policy.

Elaboration of Policy

Any person who wishes to report suspected violations may do so by several different means. It is always recommended that reports be written. Written reports may be submitted to the appropriate vice president or dean with reporting authority over the area of concern.

The college has also created an anonymous reporting mechanism. The establishment of an anonymous “whistleblower” reporting mechanism will allow employees or others to anonymously report problems to management.

Consequently, the College has contracted with a third-party report recipient, called EthicsPoint, who will accept and process anonymous reports. Reports may be filed concerning matters involving various financial risks, environmental and safety matters as well as data privacy, conflict of interest and other issues.

If an individual wishes to make an anonymous report, instructions regarding the types of issues that may be reported anonymously and the procedures for making such a report may be found online at www.middleburycollege.ethicspoint.com or call the College hotline to report improper activities at 1-866-593-6965. The hotline is independently operated to help ensure confidentiality.

This policy does not fundamentally change the responsibility for conducting investigations. Individual employee grievances and complaints regarding terms and conditions of employment will continue to be reviewed under the applicable academic and staff personnel policies. The College retains the right to close a report within 30 days if insufficient information has been provided.

Whistleblowers shall refrain from obtaining evidence for which they do not have a right of access. Such improper access may itself be considered an improper activity.

Whistleblowers are “reporting parties,” not investigators. They are not to act on their own in conducting any investigation activities, nor do they have a right to participate in any investigative activities other than as requested by investigators.

Any charges of faculty misconduct brought as a result of an investigation under this policy shall comply with established faculty conduct procedures.

Consultation with the College’s general counsel is required before negotiating or entering into any restitution agreement resulting from the findings of an investigation.

Contacts

For questions about the policy, contact:

Enterprise Risk Management
Old Chapel
Middlebury, VT 05753
Phone: 802-443-5001
vprisk@middlebury.edu

Code of Conduct for Employees

https://www.middlebury.edu/pages/ii-ug-college-policies/commun-policies/empl-conduct

Misconduct in Research – Policies and Procedures

https://www.middlebury.edu/pages/ii-ug-college-policies/faculty/research-misconduct

Anti-Harassment and Discrimination Policy

Anti-Harassment and Discrimination Policy

Updated May 3, 2019