Protection of Employees Reporting Financial Misconduct
At Hamilton, responsibilities and decision-making are distributed throughout the organization. While we trust our employees to understand and abide by policies and the law, there may be rare instances of improper, even illegal, activity.
Any employee who observes financial activities or practices that he or she believes to be against the law or violations or suspected violations of College policy must report these activities. Employees may report concerns regarding financial, accounting, internal controls, auditing and compliance matters to his or her supervisor, the Associate Vice President for Finance and Controller, or the Trustee chair of the Audit Committee, in care of the President’s Office. Reports may also be made anonymously by following the link under “Reporting Ethics Violations Concerns” under Hamilton Policies on the Human Resources website.
Reports of questionable activities or practices under this policy are deemed to be confidential communications. An employee may choose to make his or her report anonymously. To the greatest extent possible within the boundaries of applicable law, care will be taken to maintain appropriate confidentiality of reports made under this policy.
The College will take all necessary steps to ensure that employees who report questionable activities or practices will be protected from retaliation. This protection is afforded to all employees who communicate information in good faith and through appropriate channels, including directly to the Associate Vice President for Finance and Controller.
The College intends to monitor adherence by all employees to financial policies. To this end, alternative mechanisms for reporting on activities or practices by the key individuals responsible for carrying out this policy have been established. Information regarding actions of the Associate Vice President for Finance and Controller should be reported directly to the Vice President for Administration and Finance. Information regarding actions of the Vice President for Administration and Finance should be reported directly to the President. Information regarding actions of the President should be reported to the Vice President for Administration and Finance, the Associate Vice President for Finance and Controller, or the Trustee chair of the Audit Committee, any of whom may consult with the Board of Trustees.
The Associate Vice President for Finance and Controller is generally responsible for receiving all such information and investigating specific issues. The results of any investigation will be reported to the Vice President for Administration and Finance, to the President, and to the chair of the Audit Committee of the Board of Trustees. Appropriate action commensurate with findings will be taken by the College.