Whistle Blower Policy

Bethel University and Bethel University Foundation (hereinafter referred to as “Bethel”) are committed to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, this policy aims to provide avenues for employees to raise concerns about suspected misconduct, dishonesty, and fraud and to provide assurance that employees will be protected from reprisals for whistleblowing in good faith.

Encouragement of Reporting

Bethel encourages complaints, reports or inquiries about illegal practices or serious violations of Bethel’s policies including illegal or improper conduct by Bethel itself or its employees. Appropriate subjects to report under this policy would include financial improprieties, accounting or audit matters, ethical violations, conflicts of interest, or other similar illegal or improper practices. This policy is intended to encourage and enable employees and others to raise concerns within the organization prior to seeking resolution outside the organization.

Other subjects with existing complaint mechanisms should be addressed under those mechanisms (for example, raising matters of alleged discrimination or harassment via the Office of Human Resources) unless those channels are themselves implicated in the wrongdoing. This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.

Employee Refusal to Act

In rare instances an employee may feel compelled to refuse an order issued by his or her superior or supervisor at Bethel, on the grounds that the employee has a good faith objective basis in fact to believe that the order, if obeyed, would require the employee to act in an unethical, immoral, or illegal manner. In such a case, the employee shall immediately inform Bethel as set forth herein of the employee’s refusal and the complete reasons, therefore. No retaliation, harassment or disciplinary action shall be taken against the employee in any such case.

Reporting a Complaint

Anyone reporting a complaint must be acting in good faith and have reasonable grounds for believing that the information disclosed indicates a violation of law or policy.

Complaints, reports, or inquiries may be made under this policy on a confidential or anonymous basis.

Complaints should describe on a timely basis and in detail the specific facts demonstrating the basis for the complaint.

Complaints should be sent in a sealed envelope marked “Confidential” to the President. If the President is implicated in the complaint the envelope should be directed to the Bethel University Board of Trustees Audit Committee.

All complaints will be investigated and reported to either the Bethel University Board of Trustees Audit Committee and/or the Bethel Foundation Board of Governors, as applicable.

Investigating the Concern

Bethel will conduct a prompt, discreet, and objective review or investigation of all complaints including an acknowledgement of receipt to the complainant if identified.

Reporting individuals may be expected to cooperate in internal investigations of misconduct.

Subject to legal constraints, the complainant will receive information about the outcome of any investigations.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to investigate and prevent or correct the action.

Safeguards

No person shall suffer harassment, retaliation, or adverse employment consequences for reporting in good faith what s/he perceives to be wrongdoing, violations of law, or unethical conduct. This protection extends to those whose complaints are made in good faith but prove to be mistaken.

An employee who retaliates against someone who has reported a violation in good faith will be subject to discipline.

Persons who make bad faith, knowingly false, or malicious complaints, reports, or inquiries, or otherwise abuse this policy will be subject to discipline.

This policy supersedes and replaces in its entirety any prior policy. Bethel University and Bethel University Foundation reserve the right to modify or amend this policy at any time.