Whistleblower Policy

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, 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.  The Board has adopted and management has implemented the following procedure to effectively implement such safeguards.

Procedure for Reporting Financial, Auditing, or Governance Improprieties

If a trustee, administrator, employee, program 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, that person must report the concern immediately, either in person or anonymously in writing.  If the person with the concern is an employee, program employee, or volunteer, s/he should report the concern 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.

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 conflict of interest, business credit card use, or personal order policies
  • 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

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:  James Stokes, jstokes@mgslaw.net, or call 655-3463.

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), Board officers (conflict of interest or administration concerns), or administration (concern involving staff).  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 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 individual making the report will not be dismissed, harassed, or discriminated against for reporting in good faith what they perceive to be an impropriety.  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 September 15, 2009

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