WHISTLEBLOWER POLICY
As
beneficiaries of the public trust and stewards of public monies, Morrisville
Public Library must be the pinnacle of sound financial, auditing, and
management standards and practices. As
such, Morrisville Public Library’s trustees, administrators, employees, program
employees, and volunteers must comply with applicable laws and regulations and
must faithfully implement and/or adhere to the library’s own policies and
procedures. This is particularly true with
regard to matters and controls that impact the library’s finances, audits, and
governance.
Trustees,
administrators, employees, program employees, and volunteers have the
responsibility to report any circumstances that they have actual knowledge of or
a reasonable good faith belief that the library’s internal controls, auditing
function, accounting systems, or governance policies are compromised or
threatened or contrary to prescribed procedure or policy. The Board has adopted and management has implemented
the following procedure to effectively implement such safeguards.
Procedure
for Reporting Financial, Auditing, or Governance Improprieties
If
a trustee, administrator, employee, program employee, or volunteer becomes
aware of, or has a reasonable good faith belief that, the library’s internal
controls, auditing function, accounting systems, or governance policies are
compromised, threatened, or contrary to prescribed procedure or policy, that
person must report the concern immediately, either in person or anonymously in
writing. If the person with the concern
is an employee, program employee, or volunteer, s/he should report the concern
to a supervisor, who will immediately share it with an administrator. If the administrators are involved in the
concern, the supervisor will report it directly to a trustee on the appropriate
committee. If the person with a concern
is a trustee, s/he shall immediately report it to an officer of the Board.
Examples
of such improprieties include, but are not limited to, the following:
If
a trustee, administrator, employee, or program employee does not believe the
normal channels of communication can or should be used to express concerns
about or knowledge of improprieties, the complaint should be immediately
reported to the following legal counsel:
James Stokes, jstokes@mgslaw.net,
or call 655-3463.
An
investigation of the report will be undertaken by the appropriate person(s),
which is determined by the type of concern or complaint and the person(s)
suspected of improprieties. There are a
number of appropriate persons to oversee an investigation including, but not
limited to, the audit committee (auditing functions or accounting systems),
Board officers (conflict of interest or administration concerns), or
administration (concern involving staff).
The complaint, all steps of the investigation, and the resolution or
findings will be documented in a written file to be kept indefinitely in the
library’s official record. If the
concern was not submitted anonymously, the investigator must acknowledge
receipt of the complaint within fourteen days.
Under
this policy, those who report suspected improprieties are protected from
retaliation. The matter will be treated
as confidential to the greatest extent possible, consistent with the need to
investigate and prevent or correct the suspected action(s). The individual making the report will not be
dismissed, harassed, or discriminated against for reporting in good faith what
they perceive to be an impropriety.
However, persons who make unfounded allegations that have proven to have
been made recklessly, maliciously, or with the foreknowledge that the concern
expressed was false, will be subject to disciplinary action. In addition, anyone who retaliates against an
individual who reports a suspected concern will be subject to disciplinary
action.
Approved September 15, 2009