As beneficiaries of the public trust and stewards of public monies, Morrisville Public Library must be the pinnacle of sound financial, auditing, and management standards and practices. As such, Morrisville Public Library’s trustees, administrators, employees, program employees, former employees, and volunteers must comply with applicable laws and regulations and must faithfully implement and/or adhere to the library’s own policies and procedures. This is particularly true with regard to matters and controls that impact the library’s finances, audits, and governance.
Trustees, administrators, employees, program employees, and volunteers have the responsibility to report any circumstances that they have actual knowledge of or a reasonable good faith belief that the library’s internal controls, auditing function, accounting systems, or governance policies are compromised or threatened or contrary to prescribed procedure or policy, or that there is fraud or illegal activity taking place within the library. The Board has adopted and management has implemented the following procedure to effectively implement such safeguards. To assure awareness and compliance with this policy, it is provided (with acknowledgment), to each trustee, employee, program worker, and volunteer at election, hire, or commencement of service.
Procedure for Reporting Financial, Auditing, or Governance Improprieties
If a trustee, administrator, employee, program employee, former employee, or volunteer becomes aware of, or has a reasonable good faith belief that, the library’s internal controls, auditing function, accounting systems, or governance policies are compromised, threatened, or contrary to prescribed procedure or policy, or that there is fraud or illegal activity taking place within the library, or that the library’s activities violate any law, rule, or regulation or pose a substantial and specific danger to public health and safety, that person must make a good faith effort to report the concern to the Library, either in person or anonymously. If the person with the concern is an employee, program employee, former employee, or volunteer, the concern is reported to a supervisor, who will immediately share it with an administrator. If the administrators are involved in the concern, the supervisor will report it directly to a trustee on the appropriate committee. If the person with a concern is a trustee, s/he shall immediately report it to an officer of the Board. If the concern is from a trustee about another trustee, administration receives the complaint. If the person reporting reasonable believes that the violation poses imminent danger to public, health or safety, is already known to library management who refuses to address it, will result in physical harm, or that evidence may be destroyed, a good faith effort to report immediately is not required.
Examples of such improprieties include, but are not limited to, the following: Supplying false or misleading information on the library’s financial documents, including the tax return (990) Supplying false information to or withholding material information from the library’s auditors Violation of the business credit card use policy Library assets being used for personal gain or benefit Payment for services or goods that are not rendered or delivered Embezzlement Planning, facilitating, or concealing any of the above Failing to comply with applicable OSHA or Department of Health regulations
If a trustee, administrator, employee, or program employee does not believe the normal channels of communication can or should be used to express concerns about or knowledge of improprieties, the complaint should be immediately reported to the following legal counsel: Paula Highers, 315-471-1664, phighers@mcvlaw.com.
An investigation of the report will be undertaken by the appropriate person(s), which is determined by the type of concern or complaint and the person(s) suspected of improprieties. There are a number of appropriate persons to oversee an investigation including, but not limited to, the audit committee (auditing functions or accounting systems, fraud), Board officers (conflict of interest or administration concerns), or administration (concern involving staff). The matter will be treated as confidential to the greatest extent possible, consistent with the need to investigate and prevent or correct the suspected action(s). The complaint, all steps of the investigation, and the resolution or findings will be documented in a written file to be kept indefinitely in the library’s official record. If the concern was not submitted anonymously, the investigator must acknowledge receipt of the complaint within fourteen days.
Under this policy, those who report suspected improprieties are protected from retaliation. The individual making the report will not be intimidated, harassed, discriminated against or, if the reporter is an employee, will not suffer actual or threatened adverse employment consequences for reporting in good faith what they perceive to be an impropriety. In addition, an employee or former employee reporting suspected improprieties will not suffer real or threatened actions that would adversely impact current or future employment. Morrisville Public Library will also not retaliate by contacting or threating to contact authorities to report actual or suspected immigration status of the current or former employee or their family members. Morrisville Pubic Library will not participate in illegal retaliation.
However, persons who make unfounded allegations that have proven to have been made recklessly, maliciously, or with the foreknowledge that the concern expressed was false, will be subject to disciplinary action. In addition, anyone who retaliates against an individual who reports a suspected concern will be subject to disciplinary action.
Approved by Board of Trustees: 9/15/09; amended 3/17/22
