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SUNY College at Oneonta Alumni Association, Inc.
Code of Conduct;
Protection Against Retaliation for Whistle-blowers;
and Procedures for the Receipt of Complaints

Policy Statement:  In keeping with the policy of maintaining high standards of conduct and ethics, the Association will investigate any suspected fraudulent or dishonest use or misuse of the Association's resources or property by staff, Board members, consultants, auditors or volunteers. The Association is committed to maintaining the highest standards of conduct and promotes a working environment that values respect, fairness and integrity. All staff, Board members and volunteers shall act with honesty, integrity and openness in all their dealings as representatives for the Association. Failure to follow these standards will result in disciplinary action, including possible termination of employment, dismissal from the Board, or possible civil or criminal prosecution if warranted.

Reporting: Staff, Board members, consultants or auditors are encouraged to report suspected fraudulent or dishonest conduct (i.e., to act as "whistle-blower"), pursuant to the procedures set forth below. Any concerns or complaints about possible fraudulent or dishonest use or misuse of resources or property should be reported to that person's supervisor. If, for any reason, a person finds it difficult to report his or her concerns to a supervisor, that person may report the concerns directly to the Director of the Association, to the President of the Board or to the Chair of the Board's Finance Committee. Anonymous reports may be submitted in writing to one of the individuals listed.

Fraudulent or Dishonest Conduct: A deliberate act or failure to act with the intention of obtaining an unauthorized benefit may be the subject of a concern or complaint regarding the accounting or fiscal matters of the Association. Examples of such conduct include, but are not limited to:

  • forgery or alteration of documents;
  • unauthorized alteration, manipulation or destruction of computer files;
  • fraudulent financial reporting;
  • misappropriation or misuse of Association resources, such as funds or other assets; or
  • authorizing or receiving compensation for goods not received or services not performed.

Rights and Responsibilities: No person will be subject to retaliation because of a good faith report of a concern or complaint regarding accounting or fiscal matters or any alleged violation of law pertaining to the management of the Board's funds and its assets. Supervisors are required to immediately report suspected fraudulent or dishonest conduct to the Director of the Association or to the President of the Board.

Procedures for Complaints: The submission of concerns or complaints that address accounting or fiscal matters may be submitted by individuals to the Director of the Association, the President of the Board or to the Finance Committee Chair. All complaints will be filed with the Chair of the Finance Committee. Upon receipt of a concern or complaint, the Finance Committee Chair will acknowledge its receipt, in writing, to the person who submitted the matter. The Finance Committee Chair will inform the Finance Committee of all concerns and complaints regarding accounting or fiscal matters in compliance with the Sarbanes-Oxley Act of 2002 and will provide written reports to the Finance Committee, as appropriate.

The Finance Committee will investigate any report regarding accounting or fiscal matters relating to defalcations, thefts or fraud, with the assistance of any managerial employees of the Association or College, auditors or counsel, as it deems appropriate. Confidentiality will be maintained to the extent possible, consistent with applicable law and policy.

If the investigation of the concern or complaint indicates that a violation of law, regulations or policy has occurred, the Finance Committee Chair may present the findings of the investigation to the Association's Board of Directors and to the College's Associate Vice President for Employee Services. The Director of the Association, in conjunction with President of the Board, will determine appropriate disciplinary measures or other corrective action in accordance with the policies of the State University of New York College at Oneonta Alumni Association, Inc., the College, and as required by law.

Record-keeping: The Finance Committee Chair will maintain a record of all concerns and complaints that relate to accounting or fiscal matters regarding defalcations, thefts or fraud that have been received since the adoption of this policy. The Finance Committee shall track the receipt, investigation and resolution of all such concerns and complaints, and the Finance Committee Chair shall provide periodic reports to the Board. Copies of records relating to concerns and complaints received will be maintained in accordance with the Board's records retention policy.

Baseless Allegations: Persons who make allegations with a reckless disregard for the truth may be subject to disciplinary action by the Association or the College and legal claims by individuals accused of such conduct.

A motion to adopt this policy was unanimously passed by the Executive/Finance Committee at a meeting on 8/7/07. This policy will be circulated at the Alumni Association Board of Directors Meeting on October 12, 2007.