Whistleblower Policy

Policy Statement

Suffolk University is committed to maintaining the highest standards of ethical conduct, integrity, and accountability. As part of this commitment, we encourage the reporting of any misconduct or unethical behavior that may occur within the University community. This Whistleblower Policy (“Policy”) provides a framework for individuals to anonymously report such concerns, while also ensuring protection against retaliation for those who come forward with genuine concerns.

It is the policy of Suffolk University that all members of the University community be free to report, without fear of retaliation, activity occurring in University operations that the reporting person believes in good faith to be illegal, dishonest, unethical or fraudulent.

Reported allegations will be treated confidentially to the extent possible, and will be promptly investigated. Neither the University nor any of its employees will take adverse employment action or other action in retaliation against a person who reports in good faith information under this Policy.

Scope

This policy applies to all members of the Suffolk University community, including faculty, staff, students, contractors and volunteers.

This Policy is not intended to supplant, but rather to complement and supplement, existing University policies. Therefore, this Policy does not affect any rights, responsibilities or procedures set forth in other University policies addressing misconduct. For example, complaints or grievances such as those regarding discrimination or harassment, other personnel or employment matters, academic matters and other matters to which there are specific University policies, should ordinarily be made and addressed in accordance with the University policies applicable to such matters.

Definitions

Whistleblower
A person who acts in good faith to report observed or suspected misconduct.

Misconduct
Activity occurring within University operations which is illegal, dishonest, unethical or fraudulent behavior, including, but not limited to, misconduct related to the University’s financial, accounting or audit matters; violations of federal, state or local laws; misappropriation or misuse of University resources, including funds, supplies or other assets; extortion or bribery; forgery or alteration of University documents; fraudulent financial reporting; and authorizing or receiving compensation for goods not received, services not performed or hours not worked.

Good Faith
Having reasonable grounds to believe that the reported allegations are substantially true.

Whistleblower Protection Against Retaliation

The University encourages and protects Whistleblowers who, based on a good faith belief, report observed or suspected Misconduct occurring in University operations.

The University and its employees are prohibited from engaging in retaliation against any person who in good faith reports a concern under this Policy or who cooperates in the investigation of reported Misconduct. This includes, but is not limited to, retaliation in the form of an adverse employment action, harassing behavior, or threats of harm. Any reporting person who believes that she or he is being retaliated against should contact the Office of the General Counsel immediately so that the University may take timely and appropriate action.

Any employee who engages in retaliation against a Whistleblower or a person cooperating with an investigation under this Policy may be subject to disciplinary action up to and including dismissal from the University.

A person who makes a false report under this Policy may be subject to disciplinary action, up to and including dismissal from the University. The fact that a report does not result in a finding of Misconduct is not alone sufficient evidence that the report was not made in good faith.

Anonymous Reporting Process (Whistleblower Hotline)

Since confidentiality is an important element of this Policy, the University has contracted with an independent outside reporting service, EthicsPoint, to receive and transmit reports under this Policy both to the University’s Administrator for the Policy, who is the University’s General Counsel, and the Chair of the Audit Committee of the Board of Trustees.

Reports about alleged misconduct can be made by calling the toll-free number for EthicsPoint at 855-284-6742 or by accessing its website at www.suffolkwhistleblower.ethicspoint.com. Both reporting methods are available 24 hours a day, seven days a week throughout the year.

The report should contain as much detailed information about the alleged Misconduct as possible in order to conduct an efficient and thorough investigation. In fact, both the telephone and website methods of reporting will present interview questions to the reporter to guide the reporter through the reporting process.

Addressing Reports of Misconduct

All reports received through the Hotline will be promptly and thoroughly investigated by an appropriate administrator or their designee. Once the investigation is complete, appropriate action will be taken, which may include disciplinary measures, corrective actions, or policy changes. Except as described below, a confidential investigative report will be submitted to the applicable senior administrator and to the Chair of the Audit Committee of the Board of Trustees at the conclusion of every investigation.

Whistleblowers should not attempt to investigate the matter independently, as doing so may compromise the integrity of an official investigation.

Note: If an attorney in the Office of the General Counsel, the President and/or a member of the Board of Trustees is the subject of an allegation of Misconduct, the Chair of the Audit Committee of the Board of Trustees shall receive the report of Misconduct and will appoint individuals to substitute for the role of the Office of the General Counsel and the President in their investigative and decision-making roles. In these situations, the reporting person shall file the report by delivering it to the Audit Committee of the Board of Trustees, c/o The President’s Office.

Confidentiality of Reports and Investigations

Reports and investigations will be kept confidential to the extent possible and consistent with University policies and applicable federal, state and local laws. Although the University will endeavor to handle all reports with discretion and due regard for privacy, other obligations and considerations may preclude the University from maintaining confidentiality. For example, the following is a non-exhaustive list of situations in which the University would be required to disclose the identity of the reporting individual: 1) identification is necessary to allow the University or law enforcement officials to investigate or respond effectively to the report; 2) identification is required by law; 3) the University concludes that the person accused of Misconduct is entitled to the information; and 4) pursuant to subpoena and/or court order

Questions

Any questions or concerns regarding this Policy should be directed to the Office of the General Counsel.

Contact Information

The Office of the General Counsel is located at:

73 Tremont Street
13th Floor
Boston, MA 02108

617-725-4115

Revised 2/12/2024