Whistle Blower Policy
February 8, 2009
The Council on Undergraduate Research (CUR) requires the Board of Directors, officers, Council representatives, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of (CUR), we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
It is the responsibility of all Board and Council members, officers, employees and volunteers to report ethics violations or suspected violations in accordance with this Whistleblower Policy.
No member of the Board of Directors, officer, employee or volunteer who in good faith reports an ethics 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 and/or being barred from further involvement with CUR. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within CUR prior to seeking resolution outside the Council.
CUR has an 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 of higher authority or anyone in management whom you feel comfortable approaching. Supervisors and managers are required to report suspected ethics violations to the CUR'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 CUR's open door policy, individuals should contact CUR's Compliance Officer directly. The President of the CUR Executive Board serves as CUR's Compliance Officer for the duration of his/her term. If the President is not available, then the President-elect would be the next person to contact and he/she would fulfill the duties of the Compliance Officer.
CUR's Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his/her discretion, shall advise the Executive Officer. The Compliance Officer has direct access to the board of directors and is required to report to them at least annually on compliance activity. The CUR Compliance Officer is the president of the organization.
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 must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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.
The Compliance Officer is the current President of the CUR Executive Board.
CUR Management Staff
Policy Approved by the CUR Board of Directors on February 8, 2009