Whistleblower Policy

ARTICLE 1. PURPOSE

Wright University requires volunteers, employees, directors, officers and board members to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As volunteers, employees, and representatives of Wright University we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

ARTICLE 2. REPORTING RESPONSIBILITY

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Wright University can address and correct inappropriate conduct and actions. It is the responsibility of all volunteers, employees, directors, officers, and board members to report concerns about violations of Wright University’s code of ethics or suspected violations of law or regulations that govern Wright University’s operations.

ARTICLE 3. NO RETALIATION

It is contrary to the values of Wright University for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Wright University. 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.

ARTICLE 3. REPORTING PROCEDURE

Wright University has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. 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 the Chief Equity and Compliance Officer (CECO). Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Wright University’s CECO or Chief Human Resource Officer (CHRO) who has the responsibility to investigate all reported complaints. Volunteers and employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or to the CECO.

ARTICLE 4. EQUITY AND COMPLIANCE OFFICER

Wright University’s Equity and Compliance Officer (CECO) is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The CECO will advise the Board of all complaints and their resolution and will report at least annually to the Chief Financial Officer (CFO) on compliance activity relating to accounting or alleged financial improprieties.

ARTICLE 5. ACCOUNTING AND AUDITING MATTERS

Wright University’s CECO shall immediately notify the CFO of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

ARTICLE 6. ACTING IN GOOD FAITH

Anyone filing a written 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.

ARTICLE 7. CONFIDENTIALITY

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

ARTICLE 8. HANDLING OF REPORTED VIOLATIONS

Wright University’s CECO will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

The foregoing Policy was adopted by the Chief Officers on May 6, 2021.