Purchase College Foundation (“PCF”) is committed to the highest possible legal, ethical and moral standards of conduct and will not tolerate illegal or dishonest behavior.  In this spirit, PCF encourages its officers, trustees, vendors, volunteers and others working on PCF matters, including employees of Purchase College State University of New York (“College”), to identify any instances in which these standards may be compromised.

This Whistleblower Policy (the “Policy”) has been established to enable them to raise good faith concerns about behavior that appears to be illegal, fraudulent, dishonest or unethical. A Whistleblower is the individual reporting such activity. Examples of illegal or dishonest activities are, but not limited to, violations of federal, state or local laws; billing for services not performed or for goods not delivered; and fraudulent financial reporting.

Although the Whistleblower is not expected to prove the truth of the allegation(s), she or he must demonstrate reasonable grounds for concern.  No investigation will be made of unspecified wrongdoing or conclusory allegations. The Whistleblower is not, however, responsible for investigating the activity or for determining fault or corrective measures; appropriate Foundation officials are charged with these responsibilities.

If any person has knowledge of or a concern of illegal, dishonest or potentially fraudulent activity, the person is to contact the parties listed below.  The person must exercise sound judgment to avoid baseless allegations.  A person who intentionally files a false report of wrongdoing will be subject to appropriate disciplinary action, including removal as Trustee or officer, termination as vendor or volunteer, and in the case of a College employee, appropriate authorities at the College shall be notified of the matter.

Whistleblower protections are provided in two important areas, confidentiality and against retaliation.  Insofar as possible, the confidentiality of the whistleblower will be maintained.  However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense.  The Foundation will not retaliate against a whistleblower.  Any College employee who is a whistleblower and who believes he/she is being retaliated against must contact the Human Resources department of the College immediately.

The Board of Trustees of PCF has established the following procedures for; (a) the receipt, retention, and treatment of complaints received by the Foundation regarding accounting, internal accounting controls, or auditing matters; and (b) the submission by the Whistleblower on a confidential and anonymous basis, of concerns regarding questionable accounting or auditing matters; and (c) instances or situations involving officers, trustees or others which could raise liabilities or legal issues for the Foundation.

 

The procedures are as follows:

1. Any complaints received by anyone at the Foundation shall be sent to the Chair of the Finance Committee and to the Chair of the Board of Trustees regarding financial statement disclosures, accounting, internal accounting controls, auditing matters or liabilities or legal issues.  The Whistleblower may contact these individuals directly, also.
   
2. All concerns shall be set forth in writing and forwarded to the Chair of the Finance Committee and the Chair of the Board.  If the Whistleblower wishes to discuss the matter with these individuals, that should be indicated and a telephone number be included at which he/she can be contacted. 
   
3. A copy of the Policy is available on the Organization’s website at https://www.purchase.edu/live/blurbs/2405-whistleblower-policy.
   
4. Following the receipt of any complaints submitted hereunder, the Finance Committee will investigate each matter so reported and in consultation with the Chair of the Board, recommend to the Board of Trustees corrective and disciplinary action, if appropriate, which may include, alone or in combination, a warning letter of reprimand, removal as Trustee or officer, termination as vendor or volunteer, and in the case of a College employee, that the appropriate authorities at the College be notified of the matter.
   
5. The Finance Committee may enlist other employees of the College and/or outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding the matter.  In conducting the investigation, the Committee shall use reasonable efforts to protect the confidentially and anonymity of the complainant.
   
6. A person who is the subject of a whistleblower complaint shall not be present at or participate in Board or Committee deliberations or vote on the matter relating to such complaint, provided that nothing shall prohibit the Board or Committee form requesting that such person who is the subject of the complaint present information as background or answer questions at a Committee or Board meeting prior to the commencement of deliberations or voting relating thereto.
   
7. The Finance Committee shall retain as a part of their corporate records any such complaints or concerns for a period of no less than seven (7) years.

PCF has voluntarily adopted this policy.  No additional cause of action against the Foundation (other than already provided by law) shall result from the adoption of this policy.