Policy on Suspected Misconduct, Dishonesty, Sexual Harassment, Fraud, and Whistle-Blower Protection
Irvington Community School, Inc. (ICS) is 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, sexual harassment and/or fraud and to provide reassurance that they will be protected from reprisals or victimization for whistle-blowing in good faith.
PROCEDURE
Reporting
Employees and any other person, including but not limited to parents, students, contractors, and Board Members who have a concern relating to suspected misconduct, dishonesty, sexual harassment and/or fraud may make a report. ICS wants to hear of possible problems in these areas.
Concerns of suspected misconduct, dishonesty, sexual harassment and/or fraud may be reported by telephone, email or regular mail, at the employee’s or reporter’s preference:
A complainant may telephone the:
- ICS Interim Chairman of the Board, Jeff Lozer, at: 317-413-5113
- Chairman of the ICS Audit Committee, John Williams, at: 317-674-2019
A complainant may email directly to:
- This e-mail address is being protected from spambots. You need JavaScript enabled to view it. , ICS Interim Chairman of the Board at:
- This e-mail address is being protected from spambots. You need JavaScript enabled to view it. , Chairman of the ICS Audit Committee at:
A complainant may write a letter to:
- Jeff Lozer, ICS Interim Chairman of the Board, 8423 North Washington Boulevard, Indianapolis, IN 46240
- John Williams, Chairman of the ICS Audit Committee, 1532 Clinton Street, IN 46060
Note: All Reports received above will be forwarded to John Williams, Chairman of the ICS Audit Committee.
Timing
The earlier a concern is expressed, the easier it is to take action.
Investigating the Concern
Following the receipt of any complaints submitted, the Audit Committee will investigate each matter so reported and take corrective and disciplinary actions where appropriate.
The Audit Committee may enlist committee members, employees of the School and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding financial reporting, accounting, internal accounting controls, auditing matters, or any other form of misconduct, dishonesty, or fraud. In conducting any investigation, the Audit Committee shall use reasonable efforts to protect the confidentiality and anonymity of the complainant.
Further Information
The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the complainant.
Report to Complainant
The complainant will be given the opportunity to receive follow-up on their concern within two weeks:
- Acknowledging that the concern was received;
- Indicating how the matter will be dealt with;
- Giving an estimate of the time that it will take for a final response;
- Telling them whether initial inquiries have been made;
- and Telling them whether further investigations will follow, and if not, why.
Information
Subject to legal constraints the complainant will receive information about the outcome of any investigations.
Document Retention
The Audit Committee shall retain as a part of the records of the Committee any such complaints or concerns for a period of at least seven years.
SAFEGUARDS
No Retaliation
No director, officer, or employee or other person 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. This policy is intended to encourage and enable employees and others to raise concerns within the organization prior to seeking resolution outside the organization.
Additionally, no employee shall be adversely affected because they refuse to carry out a directive which, in fact, constitutes corporate fraud, or is a violation of state or federal law.
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 conduct an adequate investigation. Every effort will be made to protect the complainant’s identity.
Anonymous Allegations
Employees are encouraged to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, but consideration will be given to:
- The seriousness of the issue raised;
- The credibility of the concern;
- and The likelihood of confirming the allegation from attributable sources.
Acting in Good Faith
Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates misconduct, dishonesty, sexual harassment and/or fraud. 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.
DEFINITION OF TERMS
For purposes of this policy, the definition of misconduct, dishonesty, sexual harassment and/or fraud includes but is not limited to:
- Acts which are inconsistent with ICS policies
- Theft or other misappropriation of ICS assets
- Misstatements or other irregularities in ICS records
- Incorrect financial reporting
- Misuse of ICS resources
- Illegal activities
- Sexual harassment as defined by Title VII of the Civil Rights Act of 1964
- Forgery or alteration of documents
- Any other form of fraud
