Non-Retaliation/Protection for Whistleblower

Policy no. I-11
Effective date: 01/01/2008
Scope: faculty, executive staff, senior staff, staff, and student employees

Definitions

"Whistleblower" for the purpose of this policy is defined as an employee of Case Western Reserve University who reports an activity that he/she believes in good faith to be illegal, dishonest, discriminatory, or fraudulent or otherwise violates a university policy.

Policy Statement

The university strives to provide a positive, productive work environment in which employees are encouraged to report issues and concerns about their work environment or the university. If an employee has knowledge of or information that illegal, dishonest, discriminatory, or fraudulent activity has occurred, or a violation of university policy has occurred, the employee is to contact his/her immediate supervisor, Employee Relations, or the Integrity Hotline to report the activity or incident. Examples of illegal, dishonest, or fraudulent activities are: violations of federal, state, or local laws; billing for services not performed or for goods not delivered; and other fraudulent or improper financial reporting.

Individuals are encouraged to report their concerns first to their supervisor or to another appropriate university official. However, if that is not a viable option, or if the individual believes his/her concerns are being ignored, he/she can report any concerns to a university office such as Audit Services, Employee Relations, Equal Opportunity & Diversity, Protective Services, Office of General Counsel, or Research Compliance. If the individual is uncomfortable discussing his/her concerns with a university official, the university has engaged Global Compliance to be its third party ethics and compliance hotline provider, 1-866-483-9367. Efforts will be made to perform investigations discreetly. The details of the investigation will be kept confidential, to the extent feasible, and consistent with university policies and applicable federal, state, and local laws.

Whistleblower protections are provided against retaliation. University employees are prohibited from retaliation against or any form of harassment of an individual who reports a concern in good faith. Any employee who engages in retaliation or harassment against a reporter may be subject to corrective action up to and including termination. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation reductions, or poor work assignments, or threats of physical or mental harm. Any whistleblower who believes he/she is being retaliated against must contact Employee Relations or the Integrity Hotline immediately so that the university may take appropriate action.

The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing of the whistleblower that is found to exist following an investigation.

All reports of illegal, dishonest, or fraudulent activities should be promptly submitted to Employee Relations, which is responsible for investigating and coordinating corrective action.

The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing may be subject to corrective action up to and including termination.

Employees with any questions regarding this policy should contact Employee Relations.

Policy Administration: Audit Services, Equal Opportunity and Diversity, Protective Services, Office of General Counsel and Research Compliance

References: Confidentiality (I-12), Positive Corrective Action (III-3), Integrity Hotline.