||Director of Human Resources
|Date of Approval:
||September 13, 2016
|Date of Last Revision:
||November 28, 2011
|Next Review Date:
Heritage University’s Code of Ethics and Conduct (“Code”) required directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.
Reason for Policy/Purpose
As employees and representatives of Heritage University, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
Who Needs to Know this Policy
This policy applies to all University directors, officers and employees of Heritage University.
Website Address for this Policy
Compliance Officer – Chief Financial Officer
It is the responsibility of all directors, officers and employees to comply with the Code and to report violations or suspected violations in accordance with the Whistle-Blower Policy.
No director, officer or employee who in good faith reports a violation of the Code 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 Whistle-Blower Policy is intended to encourage and enable employees and others to raise serious concerns within the University prior to seeking resolution outside the University.
The Code addresses Heritage University’s open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with someone in the Human Resources Department or anyone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code of Conduct to the Heritage’s Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied or uncomfortable with following the University’s open door policy, individuals should contact University’s Compliance Officer directly.
Heritage University’s Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the University President and/or the audit committee. The Compliance Officer has direct access to he Finance Committee of the Board of Directors and is required to report to the Finance Committee at least annually on compliance activity. The Organization’s Compliance Officer is a member of the Finance Committee.
Accounting and Auditing Matters
The Finance Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Finance Committee of any such complaint and work with the Committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code. 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.
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.
Handling of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
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