Purpose

Lindenwood University takes seriously its responsibility for the stewardship of University resources and the public and private support that helps enable Lindenwood to pursue its mission. Consistent with this position, the University is committed to the highest ethical and professional standards of conduct. As a result, the University requires its directors, officers, employees, student workers, interns, and volunteers to observe high standards of business and personal ethics in performance of their duties on the University’s behalf. Additionally, the University requires all individuals identified above to conduct their duties in compliance with all applicable laws, rules, regulations, policies, and the Employee Code of Ethics. This policy also sets forth the process for receiving and addressing reports of improper conduct at the University covered by this policy.

Scope

This policy applies to all activities of the University and to the conduct described herein.

Policy

As a general matter, the University’s internal controls and operating procedures are designed to detect and prevent improper use of University resources, misappropriations of University property, and improper commercial business transactions and/or activities. However, even the best systems cannot provide absolute safeguards against all such instances. Both intentional and/or unintentional violations of laws, regulations, policies, and procedures may occur and may constitute improper conduct as set forth in this policy. Below is a non-exhaustive list of improper conduct covered by this policy and prohibited by the University:

• Falsification, forgery, or alteration of records, contracts, or documents;
• Unauthorized use, alteration, or manipulation of electronically stored information;
• Improper or fraudulent financial and accounting practices or reporting;
• Pursuit of a personal benefit or advantage as a result of a conflict of interest;
• Misappropriation, misuse, or theft of University resources, such as funds, supplies, or other assets;
• Authorizing or receiving compensation for goods not received or services not performed;
• Authorizing or receiving compensation for hours not worked (payroll and timekeeping abuse);
• Engaging in or allowing others to engage in dishonest or prohibited activities;
• Circumvention of internal financial controls;
• Embezzlement;
• Improper giving/receiving of gifts;
• Circumvention of IT security;
• Other conduct contrary to the best interests of the University.

Reports

For purposes of this policy, the University has defined a “whistleblower” as someone who discloses, by virtue of using this policy to report information or activity related to the intentional and unintentional violations of laws, regulations, policies, and procedures (including, but not limited to, the improper activities and conduct listed in this policy).  The University has an “open door” policy and process by which it receives and timely responds to reports of instances of potential improper conduct. Employees are encouraged to share their questions, concerns, suggestions, and/or complaints with a person who can address it properly.

An employee may direct concerns to their supervisor. In most situations, an employee’s supervisor is in the best position to address an area of concern and may possess subject matter expertise on the topic of the report. If an employee is not comfortable speaking with their supervisor, if their supervisor is the subject of their concern, or if the employee is not satisfied with the supervisor’s response, the employee is encouraged to speak to the Human Resources Department. Supervisors who receive a report of this nature should also inform Human Resources Department as soon as possible to help ensure an appropriate response.

Concerns relating to financial reporting, potential unethical conduct, or potential illegal conduct may reported directly to the University’s general counsel’s office. They can also be reported to Lighthouse Services, the University’s independent and confidential reporting service. Lighthouse will review each report and coordinate with appropriate personnel of the University. Lighthouse can be reached using the following methods:

• Website: Syntrio
• Toll-Free Telephone: 1-844-700-0014
• E-mail: reports@lighthouse-services.com
  (must include company name with report)
• Fax: (215) 689-3885
  (must include company name with report)

In all instances, the University retains the discretion to determine when circumstances warrant an internal or external investigation and, in conformity with this policy and applicable laws and regulations, the appropriate responsive action.

Timing

The University encourages the prompt reporting of incidents potentially arising under this policy in order to maximize the University’s ability to respond promptly and effectively. The University, however, does not limit the timeframe for reporting; however, delays in reporting may negatively affect the investigation’s scope and/or ability to timely remedy a situation.

Good Faith Basis

Anyone reporting a concern is expected to do so in good faith and have reasonable grounds for believing that the information they are providing may indicate a violation of laws, regulations, policies, and/or the Employee Code of Ethics. Any reports that prove to have been made maliciously, including those that were known to be false when made, will be deemed a violation of the Employee Code of Ethics, and will be subject to disciplinary action. Although a reporting employee should not, and is not, expected to undertake their own investigation or to prove the ultimate truth of a report, the employee should have a reasonable and good faith belief that grounds for potential concern exist.  Any documentation or other evidence in the employee’s possession related to the report should also be provided in the report.

No Retaliation

No director, officer, administrator, or employee who in good faith reports a violation of this policy shall suffer harassment, retaliation, or any adverse employment consequence as a result of their good faith report. Harassment or retaliation against a person because of their good faith report of this policy is strictly prohibited, and may result in discipline, up to and including termination of employment. This policy is intended to encourage and enable employees and others to raise concerns within the University prior to seeking resolution from outside sources.

Confidentiality

To the extent possible, within the limitations of law, policy, and the need to conduct a competent investigation, confidentiality of the reporting parties will be maintained. Please note that the information provided in a Lighthouse hotline report may be the basis of an internal and/or external investigation by the University into the issue being reported. Reporting parties should be cautioned that their identity may become known for reasons outside of the control of the investigator, University administrators, or as a result of an internal and/or external investigation.

Anonymous Allegations

The policy allows employees to remain anonymous at their option (based on limitations previously noted). Initial inquiries will be made with anonymous reports, but consideration will be given to:

• The seriousness of the issue raised;
• The credibility of the concern; and
• The likelihood of confirming the allegation from reliable sources.

Response to Reports

Reports of alleged violations of this policy will be timely evaluated by appropriate University officials. Depending on the nature of the report, some reports may be resolved informally without a formal investigation. On the other hand, some reports may necessitate a formal investigation.

The individual submitting a report will be provided with the opportunity to indicate their willingness to assist further in the investigatory process, including by providing additional details and information, with the understanding that the University’s ability to respond to a report may be limited if the person making the report requests his/her name, or other identifiable information, not be disclosed.

Although the University appreciates reporting under this policy, the university may be prohibited under certain laws, regulations, policies, or circumstances from disclosing the outcome of an investigation.

This policy is not intended to take the place of the policy and process for reporting potential violations of the University’s applicable employee policies, including for reporting issues related to alleged employment discrimination, harassment, or retaliation, which are covered in the Employee Non-discrimination and Non-Harassment Policy. Title IX of the Education Amendments of 1972 (“Title IX”) covers sexual harassment that meets specific definitions according to the Title IX regulation. Additional Title IX information is found in the Title IX Policy.