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Resources and Ways to Report

All members of the College Community are encouraged to report violations or suspected violations of law, rule, or regulation or College policy. There are two ways that any individual can make such a report:

  1. to the Compliance Officer by e-mail, whistleblower@strose.edu, or by hard-copy letter mailed to them through interoffice mail with their name and title, or regular mail using the College’s mailing address:
    • The College of Saint Rose,
      432 Western Avenue,
      Albany, N.Y. 12203.

    If the Compliance officer is the subject of the report, then the report should be made to President at President@strose.edu.

  2. by using the College’s anonymous hotline at 518.454.5275 or via email at: anonymous@strose.edu, or by using the anonymous reporting form in the College website. Anonymous reports will be referred to the Chief Compliance Officer.

Reporting Individuals outside of the College Community:
Individuals outside of the College Community who wish to report Misconduct or suspected Misconduct may use the College’s anonymous hotline at 518.454.5275 or via email at: anonymous@strose.edu, or use the anonymous reporting form in the College website.

Access the Anonymous Reporting Form:

View related policies:

Whistle Blower Policy

Approved: Board of Trustees, February 11, 2022

Purpose:
This Whistleblower Policy (“the Policy”) is adopted by the Board of Trustees (“the Board”) of The College of Saint Rose (“the College”). This Policy requires all Trustees, Employees (as defined below), and volunteers (hereinafter referred to collectively as the “College Community”) to observe high ethical standards in the conduct of their duties and responsibilities. The College is committed to compliance with all applicable laws, rules, and regulations. Additionally, the College is committed to establishing policies and procedures that interpret and apply these laws, rules, and regulations in the College setting. The College has established internal controls and operating procedures to detect and prevent or deter improper activities. Nevertheless, even the best systems of control cannot provide absolute safeguards against improper behavior. Accordingly, the College is implementing this Whistleblower Policy (the “Policy”) to address how to report improper activities by a member of the College Community.

The primary purpose of this Policy is to provide a process for members of the College Community and others to report to the College Misconduct or suspected Misconduct. “Misconduct” is a violation of law, rule, or regulation, or any adopted policy of the College. This Policy also provides a process for the College to investigate and to address reports of Misconduct or suspected Misconduct. This Policy further serves to protect from retaliation, in any form, those who report Misconduct or suspected Misconduct in good faith.

Definitions:

  1. Complainant: Any person, whether a member of the College Community or not, who reports Misconduct or suspected Misconduct pursuant to this Policy.
  2. Employee: Any person who performs services for and under the control and direction of the College for wages or other remuneration, including former employees, or natural persons employed as independent contractors. This includes all of the College’s Key Persons and employees (full-time, visiting and adjunct faculty (and full or part-time staff and administrators).
  3. Key Person: Any person, other than a Trustee or officer, whether or not an employee of the College, who (i) has responsibilities, or exercises powers or influence over the College as a whole similar to the responsibilities, powers, or influence of Trustees and officers; (ii) manages the College, or a segment of the College that represents a substantial portion of the activities, assets, income or expenses of the College; or (iii) alone or with others controls or determines a substantial portion of the College’s capital expenditures or operating budget. For clarity, currently, the College considers the following position titles to be Key Persons: Deans, Director, Executive Director, Associate or Assistant Vice President, Vice President.
  4. Good Faith: Information concerning potential wrongdoing is disclosed in “good faith” when the individual making the disclosure reasonably believes such information to be true and reasonably believes that it constitutes Misconduct or potential Misconduct.
  5. “Laws, rules, and regulations”: include: (1) any duly enacted federal, state or local statute or ordinance or executive order; (2) any rule or regulation promulgated pursuant to such statute or ordinance or executive order; or (3) any judicial or administrative decision, ruling or order.

Policy:
This Policy governs the reporting and investigation of violations and suspected violations of law, rule, or regulation, or any adopted policy of the College. The administrator of this Policy is the Chief of Staff in the Office of the President (the “Compliance Officer”). The Compliance Officer shall report on compliance activity to the College’s Board of Trustees Audit Committee. This Policy does not replace, but rather supplements, all other existing College policies. The College has separate policies and procedures for discrimination and harassment complaints. Complaints regarding sexual harassment should be submitted to the College’s Title IX Coordinator, under the Title IX Grievance Policy, available here: https://strosemedia.s3.amazonaws.com/wpcontent/uploads/2021/09/07160636/Title-IX-Grievance-Policy-9.7.21.pdf, and/or to a Designated Official under the College’s Sexual Harassment Prevention Policy, available here: https://strosemedia.s3.amazonaws.com/wp-content/uploads/2021/09/10162257/SexualHarassment-Prevention-Policy.pdf. Complaints regarding bias, harassment, or discrimination other than sexual harassment should be made to the Bias Response Team under the College’s Bias

Response Policy:
https://strosemedia.s3.amazonaws.com/wp-content/uploads/2020/09/04121314/Bias-Response-Policy-The-College-of-Saint-Rose-9-4-2020.pdf. If a discrimination or harassment complaint is submitted under this Policy, the complaint will be referred to the appropriate official to handle under the applicable policy.

Procedures:

Reporting: All members of the College Community are encouraged to report violations or suspected violations of law, rule, or regulation or College policy. There are two ways that any individual can make such a report:

  1. to the Compliance Officer by e-mail, whistleblower@strose.edu, or by hard-copy letter mailed to them through interoffice mail with their name and title, or regular mail using the College’s mailing address: The College of Saint Rose, 432 Western Avenue, Albany, N.Y. 12203. If the Compliance officer is the subject of the report, then the report should be made to President at President@strose.edu.
  2. by using the College’s anonymous hotline at 518.454.5275 or via email at: anonymous@strose.edu, or by using the anonymous reporting form in the College website. Anonymous reports will be referred to the Chief Compliance Officer.

The most effective investigations are based on the timely receipt of evidence, so Complainants are encouraged to make reports as soon as a violation is suspected, with as much information as possible. Complainants are encouraged to use the “Report of Suspected Violation under the College Whistleblower Policy” form attached to this policy or to make their best effort to provide the information requested in the form. This information can also be provided in a meeting with the Compliance Officer.

Individuals outside of the College Community who wish to report Misconduct or suspected Misconduct may use the College’s anonymous hotline at 518.454.5275 or via email at: anonymous@strose.edu, or use the anonymous reporting form in the College website.

Investigation Procedures:
If an officer or Trustee of the College or a Key Person is notified of a complaint under this Policy, they should immediately notify the Compliance Office who shall then notify the President at President@strose.edu. If the President is the subject of the complaint, the Compliance Officer shall notify the Chair of the Board and Chair of the Audit Committee at Board_Chair@strose.edu.

If the Compliance Officer is the subject of the complaint, the notification should be made directly to the President, in which case the President shall notify the Chair of the Audit Committee. If the President and the Compliance Officer are the subject of the complaint, then the notification should be made to the Chair of the Audit Committee and the Chair of the Board at Board_Chair@strose.edu.

The Compliance Officer (or the President in the event the Compliance Officer is the subject of the complaint) will determine if the complaint falls within the ambit of this Policy. If it does, the Compliance Officer shall immediately notify the Chair of the Audit Committee. If it does not, the Compliance Officer shall promptly direct the complaint to the appropriate party within the College, and provide a periodic summary to the President and the Audit Committee describing such complaints and the party to whom they were re-directed.

The President, in consultation with the Compliance Officer, will promptly determine how and in what time frame an investigation is conducted for complaints under this Policy, This includes the selection and retention of an investigator (who may be the Compliance Officer). The Compliance Officer and the President should ensure that the investigation is undertaken as quickly as possible without impairing the quality of the investigation.

If the President and/or the Compliance Officer is the subject of the complaint, the Chair of the Audit Committee and the Chair of the Board will promptly determine how and in what time frame an investigation is conducted. This includes the selection and retention of an investigator. The Chair of the Audit Committee and Chair of the Board should ensure that the investigation is undertaken as quickly as possible without impairing the quality of the investigation and that the report on the investigation is made directly to the Chair of the Audit Committee and the Chair of the Board.

Nothing within this Policy shall preclude a Complainant, the President, the Compliance Officer, the Chair of the Audit Committee, or the Chair of the Board from reporting Misconduct to appropriate external law enforcement agencies.

The investigator is responsible for interviewing witnesses and gathering information relevant to the complaint. Due to the varied nature of complaints, it is not possible to provide precise timelines for all investigations. The investigator will create a report to the Chair of the Audit Committee and the Chair of the Board rendering a finding regarding whether or not a violation of law, rule, or regulation, or College policy occurred, and, if so, recommending a plan to resolve the violation. The investigator’s report shall be submitted for review and action by the Audit Committee, which shall periodically report its findings and actions to the Board. If and when the Audit Committee deems appropriate, it may abstain from taking action on a particular matter and promptly submit the matter to the Board (via the Chair of the Board, or if the Chair of the Board is the subject of the report, to another member of the Board as appropriate) for review and action by the Board.

Once the investigation is final and the Audit Committee or the Board has determined a plan of action, and subject to any applicable confidentiality requirements, the Complainant will be advised regarding the outcome of the investigation by a designee as authorized by the Audit Committee.

All documents and evidence relating to a closed investigation will be retained in a separate file according to the College’s Records Retention Policy.

In accordance with the New York Not-For-Profit Corporation Law, in cases where reports under this Policy are discussed or voted on by the Board or a Committee of the Board, any individual who is the subject of the report shall not be present or participate in the deliberations or vote on matters relating to such report. However, nothing prohibits the Board or Audit Committee from requesting that a person who is the subject of the complaint present information as background or answer question at a Committee or Board meeting prior to the commencement of deliberations or voting relating to the report and investigation. Any Trustee who is an employee of the College shall not participate in any Board or Committee deliberations or voting relating to the administration of this Policy.

Complainant Responsibility:
The confidentiality of the Complainant making a report will be maintained to the extent practicable within the limitations of the law and the legitimate needs of the investigation. Although reports may be submitted anonymously, anonymity may hinder the investigation of the complaint. In addition, a Complainant may be required or asked to testify in court if the investigation reveals a violation of the law requiring an external adjudication.

Complainants found to have knowingly made false and baseless allegations may be subject to disciplinary action up to and including termination or dismissal from the College. A false and baseless allegation is one made with an awareness of its falsity, or one made without any substantial basis and with a reckless disregard for its truth.

No Retaliation:
No Trustee, officer, Key Person, employee or volunteer of the College who in good faith reports any Misconduct or suspected Misconduct shall be subjected to intimidation, harassment, discrimination or other retaliation, or in the case of employees, adverse employment consequence. More specifically, the College will not take any retaliatory action against an employee, because such employee does any of the following whether or not within the scope of the employee’s job duties:

  1. discloses, or threatens to disclose to a supervisor or to a public body an activity, policy or practice that the employee reasonably believes is in violation of law, rule or regulation or College policy or that the employee reasonably believes poses a substantial and specific danger to the public health or safety;
  2. provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into any such activity, policy or practice by such employer; or
  3. objects to, or refuses to participate in any such activity, policy, or practice.

Retaliatory action includes any adverse action taken by the College to discharge, threaten, penalize, or in any other manner discriminate against any employee exercising rights under this Policy, including:

  1. adverse employment actions or threats to take such adverse employment actions against an employee in the terms of conditions of employment, including but not limited to discharge, suspension, or demotion;
  2. actions or threats to take such actions that would adversely impact a former employee’s current or future employment; or
  3. threatening to contact or contacting United States immigration authorities or otherwise reporting or threatening to report an employee’s suspected citizenship or immigration status or the suspected citizenship or immigration status of an employee’s family or household member, to a federal, state, or local agency.

A member of the College Community who retaliates against a Complainant who has made a good faith report under this policy may be subject to disciplinary action, up to and including termination or dismissal from the College. Complainants who believe that they, or any of their associates, have been retaliated against under this Policy should immediately notify the President or the Compliance Officer. If the retaliation was conducted by the President or the Compliance Officer, then the report may be made to the Chair of the Audit Committee or Chair of the Board of Trustees by emailing Board_Chair@strose.edu.

Oversight:
The Compliance Officer will annually provide a report on Whistleblower Reports to the Audit Committee of the Board of Trustees. The report will document Whistleblower Reports received during the year and will provide an appraisal of the Policy’s effectiveness in receiving and investigating reports. If a complaint comes to the Compliance Officer’s attention that involves significant risk to the College’s reputation or finances, the Compliance Officer shall apprise the President and Chair of the Board of the complaint and identify the potential for such risk as soon as possible after the Compliance Officer learns of the report and its risk to the institution.

Enforcement:
Failure to comply with this Policy will be addressed through the College’s established policies and processes, including but not limited to the College’s employee handbooks, employee contracts, union contracts, and Faculty Manual or as otherwise determined by the Board. Such failure to comply may result in disciplinary action up to and including dismissal or termination of employment.

Distribution:
A copy of this Policy shall be conspicuously posted on the College’s website and distributed to all key persons, deans, directors, officers, employees, and to volunteers, and vendors who provide substantial services to the College. The link to this policy will be sent with each executed contract to applicable College vendors. For purposes of this paragraph, posting the Policy on the College’s website and in the College’s Human Resources office, Student Development office, Provost’s office, Finance and Administration office, and President’s office in conspicuous locations accessible to employees, students, and volunteers are among the methods the College may use to satisfy the distribution requirement. The College will also inform employees of their protections, rights and obligations under New York State Labor Law § 740, by conspicuously posting a notice on campus in an easily accessible and well-lighted place customarily frequented by employees and applicants for employment.

Click to access the Anonymous Reporting Form
Anonymous Reporting Form