150.010 – WHISTLEBLOWER POLICY & PROCEDURE

Updated: May 2019

POLICY
Maine Media Workshops + College seeks to follow all relevant law and the highest standard of ethical conduct and financial stewardship of its assets. In implementing this policy, Maine Media Workshops + College shall provide for an annual audit of its financial statements and operating procedures by an independent, certified public accountant; promulgate and follow codes of conduct and comply with relevant law and regulations applying to charitable, non-profit corporations; and, to the extent reasonably applicable, conform to the legal rules governing public stock corporations.

Maine Media Workshops + College shall provide a clear process for individuals or organizations to submit confidential complaints of questionable conduct by its employees or other covered individuals and maintain an accountable process for investigating and resolving such complaints. Maine Media Workshops + College will not tolerate retaliation against any person who makes a good faith report of questionable conduct. Specifically, it is the express policy of Maine Media Workshops + College that no employee or contractor may be discharged, disciplined or discriminated against in any way for making a good faith Whistleblower report or for cooperating in the investigation of such a report.

Covered Individuals
Covered individuals include, but are not limited to, Maine Media Workshops + Colleges’ at-will employees, contract employees, officers and directors, interns, and volunteers. Maine Media Workshops + College will also communicate its policy to contractors, vendors, and consultants and encourage them to report any improper or questionable practices by Maine Media Workshops + College employees or other persons associated with Maine Media Workshops + College in positions of apparent trust, responsibility or authority.

Covered Conduct
Covered conduct includes, but is not limited to, the following examples:Theft of cash, checks, or other financial instruments;

  • Failing to report a personal conflict of interest that could potentially lead to Maine Media Workshops + College financial harm.
  • Misappropriation of accounts or other items of value;
  • Unauthorized destruction of financial, project, or personnel records;
  • Making false or misleading statements to Maine Media Workshops + College managers or auditors;
  • Soliciting or receiving a bribe, unauthorized personal compensation, or future benefits in exchange for providing Maine Media Workshops + College business;
  • Theft of Maine Media Workshops + College equipment or intentional damage to Maine Media Workshops + College equipment or other property; and

PROCEDURE
Reporting Procedures
All reporting procedures described below shall provide confidentiality for the person making a good faith complaint. At the option of the complainant, he or she may remain anonymous. Any of the following processes may be used:

Confidential Complaint
A covered individual may make a confidential report in person, by telephone or by e-mail to Maine Media Workshops + College directors, including the President or Director of Finance and Administration. A report may also be made using Maine Media’s online Incident Report at www.mainemedia.edu/incidentreport. The organizations Board of Directors’ Audit Committee Chair will also be notified. The identity of the complainant shall remain confidential and the organizations directors shall not report this identity to the individual allegedly responsible for the conduct. The organization will conduct an investigation promptly and make a decision about the matter. The complainant shall be informed of the results of organization’s investigation.

Anonymous Complaint
A covered individual may make an anonymous complaint of questionable conduct by sending an anonymous written or e-mail message to the Director of Finance and Administration. A report may also be made using Maine Media’s online Incident Report at www.mainemedia.edu/incidentreport. The Business/HR Manager will forward the complaint to the appropriate directors. They will conduct an investigation promptly and make a decision about the matter.

Zero-Tolerance Retaliation Policy
Maine Media Workshops + College will not tolerate retaliation against any person who makes a good faith report of questionable conduct. It is organization’s express policy that no employee or other person may be discharged, disciplined, or in any way discriminated against for making a good faith Whistleblower report or for cooperating in the investigation of such a person. Any report of such retaliation shall be considered a complaint of covered questionable conduct and shall be investigated promptly with the results of the investigation reported to the Chairman of the Audit Committee and the Chair of the Board of Directors.