The purpose of this procedure is to establish a fair and objective mechanism for grievance and non-retaliation at the University. 

Scope

This is an institution-wide procedure, affecting all students and staff of the University. 

Referenced Laws, Regulations, and/or Policies 

This is a Parami University procedure, to comply with the University’s Grievance and Non-Retaliation policy. 

Procedures

General 

Parami University requires its Trustees, officers, volunteers and employees (“Staff”) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the University, we each must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. The Whistleblower Policy is not a vehicle for reporting violations of the University’s applicable human resources policies, problems with co-workers or managers, or for reporting issues related to alleged employment discrimination or sexual or any other form of unlawful harassment, all of which should be dealt with in accordance with the “Personnel Policies and Procedures” of the University. The matters that should be reported under the Whistleblower Policy include suspected fraud, theft, embezzlement, accounting or auditing irregularities, bribery, kickbacks, misuse of the University’s assets or suspected regulatory, compliance, or ethics-related issues, concerns or violations.

Reporting Responsibility 

It is the responsibility of all Staff of the University to report violations or suspected violations of ethical standards and/or applicable legal requirements (hereinafter referred to as “Violations”) in accordance with the University’s Grievance and Non-Retaliation Policy. 

No Retaliation 

No Staff member of the University who in good faith reports a Violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a Violation in good faith is subject to discipline up to and including termination of employment or removal from office. The Whistleblower Policy is intended to encourage and enable stakeholders and others to raise serious concerns within the University prior to seeking resolution outside of the University. 

Reporting Violations 

Questions, concerns, suggestions or complaints regarding the ethical and legal standards noted above should be addressed directly to the Chair of Parami Board of Trustees, in the event the complaint relates to the President, such questions, concerns or complaints shall be directed to the Secretary of Parami. 

Whistleblower Committee of the Parami Board of Trustees 

The Executive Committee of Parami’s Board of Trustees (President, Vice President, Treasurer and Secretary) is responsible for investigating and resolving all reported complaints and allegations 111 concerning the ethical and legal standards noted above and shall advise the Board, when appropriate, of all such complaints and allegations. The Secretary of the Parami Board of Trustees is required to report to the full Board of Trustees at least annually on compliance activity; in the event the Secretary is the subject of a complaint or allegation, the President shall make such report to the Board. 

Accounting and Auditing Matters 

The Treasurer shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing brought to its attention. The Secretary of the Parami Board of Trustees shall immediately notify the Treasurer of any such complaint and work with the Treasurer until the matter is resolved. In the event that the Secretary also holds the office of Treasurer, such notification shall be made by the President. 

Acting in Good Faith 

Anyone filing a complaint concerning a violation or suspected violation of the ethical and legal standards noted above must act in good faith and have reasonable grounds for believing the information disclosed may indicate a violation of such standards. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense. 

Confidentiality 

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. 

Handling of Reported Violations 

The President of the Parami Board of Trustees will notify the sender and acknowledge in writing receipt of the reported violation or suspected violation within five business days of receipt. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. 

Review

The Administrative and Academic Departments are responsible for ensuring compliance with this procedure in various offices of the University. 

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