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Human Resource Services

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  4. Code of Ethics

Code of Ethics and Policy on Employee Disclosure of Code Violations or Misconduct (Whistleblower and Document Integrity Policy)

 
I. Purpose and Applicability

The purpose of this Code of Ethics is to ensure that all Whitworth University employees and representatives act in accordance with the highest standards of personal and professional integrity, comply with applicable laws, rules and regulations, deter wrongdoing and comply with applicable policies and procedures adopted by the University to govern the conduct of its employees.

In addition to employees, this Code of Ethics also applies to Board of Trustee members and, to the extent in connection with their activities the University requires their agreement to comply with this Code of Ethics, student workers or interns, consultants, vendors or independent contractors, volunteers or other persons. In the case of such non-employee persons, all references in this Code of Ethics to policies and procedures of the University shall mean applicable policies and procedures adopted by the University to govern their conduct.

II.  Statement of Policy

All employees and other persons covered by this Code of Ethics agree to the following:

Conflicts of Interest

  • Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
  • Avoid conflicts of interest and to disclose to the President or his/her designee(s), Board Audit Committee or designated Board of Trustee members any material transaction or relationship that reasonably could be expected to give rise to such a conflict.
  • Comply with all applicable conflict of interest policies and procedures adopted by the University.

Compliance with Laws and Policies

  • Comply with all applicable laws, rules and regulations of federal, state, and local governments (both United States and foreign).
  • Comply with all applicable policies and procedures adopted by the University.

Reporting of Misconduct and Non-Retaliation

  • Promptly report any misconduct or violation of any such laws, rules or regulations or University policies and procedures (including this Code of Ethics) to the President or his/her designee(s), Board Audit Committee, or designated Board of Trustee members.
  • Not retaliate in any manner against any person who, upon reasonable belief, discloses an apparent violation of any such laws, rules or regulations or University policies and procedures (including this Code of Ethics) or who, following such disclosure, provides truthful information or seeks any remedy thereunder.

Confidentiality

  • Respect the confidentiality of information acquired in the course of their duties.
  • Comply with all applicable confidentiality policies and procedures adopted by the University.

Integrity of Information and Documents

  • Provide colleagues with information that is accurate, complete, objective, relevant, timely, and understandable.
  • Respect the integrity of records, documents and objects handled in the course of their duties.
  • Not knowingly alter, destroy, mutilate, conceal, cover up, falsify or make a false entry in any record, document or object with the intent to impair its integrity or availability for use in any investigation or official proceeding or to impede, obstruct or influence any investigation or attempt to do so.
  • Not impede, obstruct or influence any investigation or official proceeding or attempt to do so.

General

  • Act in good faith, with due care, competence and diligence, without misrepresenting material facts or allowing independent judgment to be subordinated.
  • Assure the ethical and responsible use of and control of all assets, resources, and information in the possession of the University and related organizations.
  • Avoid the appearance of impropriety by not accepting personal gifts or services from vendors or contractors with greater than promotional value. 

The President or the Board of Trustees Executive Committee shall have the discretionary authority to approve any deviation from or waiver of this Code of Ethics, and what actions, if any, to take in cases of apparent violations.

III.  Reporting and Disclosure of Apparent Misconduct or Violations

In the case of apparent misconduct or violations of this Code of Ethics, an employee or other person covered by this Code of Ethics shall follow the steps listed below:

  1. Report the apparent misconduct or violation and disclose all relevant information regarding evidence thereof to the President or his/her designee(s) (excluding any such designee(s) who may be involved in the misconduct or violation) promptly upon becoming aware thereof. The University encourages these reports and disclosures to be in writing in order to support accuracy and credibility, but they may be made confidentially or anonymously and may be made orally if the reporting person is uncomfortable, using the University’s Whistleblower Hotline at 833.977.5392, or using the web reporting portal at https://report.syntrio.com/whitworth. In addition, if the reporting person is more comfortable contacting a person outside the normal University administration, he or she may contact the Chair of the Board of Trustees, the Chair of the Audit Committee or any outside third party that the University may designate. If any reports or disclosures are made anonymously, these especially should contain all relevant information regarding the misconduct or violation since the University will not have an opportunity to obtain more information from the reporting person. While the University intends to take all reports and disclosures seriously, anonymous reports or disclosures may also receive more limited consideration or investigation as a result of their different and special nature.
  2. The President or his/her designee(s) shall then consider the report and disclosure and conduct whatever investigation and/or take whatever action he or she, in their judgment, determines to be appropriate under the circumstances.
  3. In the case of a report or disclosure of apparent misconduct involving the President, the report and disclosure shall be directed to the Chair of the Board of Trustees, the Chair of the Audit Committee or their designee(s). The Chair of the Board, the Chair of the Audit Committee or their designee(s) shall then consider the report and disclosure and take the appropriate actions.

IV.  Complaints of Retaliation for Reporting or Disclosure

If a University employee believes that after reporting misconduct or violations of this Code of Ethics, he or she has been retaliated against in the form of an adverse employment action such as discharge, demotion, suspension, being threatened or harassed, or in any other manner discriminated against with respect to compensation, terms, conditions or privileges of employment due to such reporting or disclosure, he or she may file a written complaint requesting an appropriate remedy by following the steps listed below:

  1. File a complaint with the President or his/her designee(s) (excluding any such designee(s) who may be involved in the retaliation) within ninety (90) days from the effective date of the adverse employment action or from the date on which the employee should reasonably have had knowledge of the adverse employment action.
  2. Complaints shall be filed in writing and shall include: (i) the name of the complainant, (ii) the name and title of the University’s official(s) against whom the complaint is being made, (iii) the specific type(s) of adverse employment actions(s) taken, (iv) the specific date(s) on which the adverse employment action(s) where taken and (v) a clear and concise statement of the facts that form the basis of the complaint, of the complainant’s explanation of how his or her reporting or disclosure of misconduct or violations is related to the adverse employment action, and of the remedy sought by the complainant.
  3. Within ninety (90) calendar days of the receipt of the complaint, the President or his/her designee(s) shall consider the complaint, shall conduct or have conducted an investigation which, in their judgment, is appropriate in the circumstances, shall make a determination regarding the complaint which, in their judgment, is appropriate in the circumstances, and shall provide the determination to the complainant. This time period may be extended by the President or his/her designee(s), in their judgment, as may be necessary or advisable to give sufficient time to complete the investigation and determination or in other appropriate circumstances.
  4. The determination shall be in writing and may include the findings of fact and the conclusions of the investigation or summaries thereof, and, if applicable, a remedy consistent with the findings and conclusions. The decision of the President or his/her designee(s) shall be final.
  5. In the case of a complaint involving the President of the University, the report and disclosure shall be directed to the Chair of the Board of Trustees, the Chair of the Audit Committee or their designee(s). The Chair of the Board, the Chair of the Audit Committee or their designee(s) shall then consider the complaint and take the actions referred to above.

This Code of Ethics, however, does not prohibit an employment action that would have been taken regardless of any reporting of misconduct or violations or disclosure of information regarding them. 

V.  Other

  1. Disciplinary actions for violation of this Code of Ethics, including retaliation against persons for reporting misconduct or violations or disclosing information regarding them, shall be determined on a case-by-case basis and may include termination of employment by the University, in addition to any other legal consequences.
  2. The various designee(s) referred to in this Code of Ethics may be appointed and changed from time to time and the University shall take appropriate steps to post or otherwise make known their names and contact information.
  3. Anyone with questions regarding this Code of Ethics or their responsibilities under it should contact Whitworth’s Business Office.

Approved by Board of Trustees on: 10/13/05 - Updated to reflect name change to Whitworth University as of 7/1/07. Updated for general review 7/1/17. Updated to reflect new whistleblower contact information 1/30/24.