Number: 545

Subject:  WHISTLEBLOWER PROTECTION POLICY

Amberton University requires Board of Trustee members, administrators, faculty, and staff to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.  All employees and representatives of Amberton University are expected to practice honesty and integrity in fulfilling responsibilities and in compliance with applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Amberton University can address and correct inappropriate conduct and actions.  It is the responsibility of all board members, officers, administrators, faculty, and staff to report concerns about violations of Amberton University’s code of ethics or suspected violations of law or regulations that govern Amberton University’s operations.

No Retaliation

It is contrary to the values of Amberton University for anyone to retaliate against any board member, officer, administrator, faculty, or staff who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Amberton University.  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.

Retaliation for Mandatory Reporting

It is a violation of Amberton’s policy to discipline or otherwise discriminate against an employee who in good faith makes a mandatory report or cooperates with an investigation, disciplinary process, or judicial proceeding relating to a mandatory report.

Reporting Procedure

Amberton University has an open door policy and suggests that employees share their questions, concerns, suggestions, or complaints with their supervisor.  If the employee is not comfortable speaking with an immediate supervisor or is not satisfied with the immediate supervisor’s response, s/he is encouraged to speak with the Vice President for Strategic Services, who is to report the situation to the President.  Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Vice President for Strategic Services, who serves as Amberton University’s Compliance Officer and has the responsibility to investigate all reported complaints.  Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Vice President for Strategic Services or the President who may at his/her discretion form a committee to investigate the concern or complaint.  Anonymous complaints may be filed using the Amberton University Anonymous Reporting Tool located on the University website under “Help and Advice” > “Sexual Assault – Title IX”

Compliance Officer

Amberton University’s Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved.  The Compliance Officer will advise the President of all complaints and their resolution and will report at least annually on compliance activity relating to accounting or alleged financial improprieties so that any complaints and their resolution may be reported to the Board of Trustees.  The Vice President for Strategic Services serves as Amberton University’s Compliance Officer.

Accounting and Auditing Matters

Amberton University’s Compliance Officer shall immediately notify the President of any concerns or complaint regarding corporate accounting practices, internal controls and work with the committee(s) formed by the President to address and resolve the concern or the complaint.

Acting in Good Faith

Anyone filing a written 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 which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant.  Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

Amberton University’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation.  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Anonymous Reporting

Anonymous complaints may be submitted using the “Anonymous Reporting Tool” located on the Amberton website under the “Help and Advice – Title IX/Sexual Assault” links.  However, anyone filing an anonymous complaint should understand that maintaining anonymity may limit the University’s ability to investigate the complaint.

Title IX Complaints

All Title IX complaints will be handled according to the regulations and procedures found in Regulation #206 and #207.