Employees of Lewis-Clark State College are expected to conduct their duties and responsibilities fairly, impartially, in an ethical manner and in compliance with applicable laws and College policies and procedures. Employees are encouraged to report suspected violations or concerns about ethical and compliance issues. Employees raising genuine concerns and making reports in good faith will be protected from retaliation.
1. Employees should follow all applicable laws and Lewis-Clark State College policies and procedures in carrying out their duties and responsibilities.
2. Employees who have ethical or compliance concerns should communicate the concerns with their direct supervisor.
3. Employees may communicate with the applicable department responsible for the area of the ethical or compliance concern.
a. Concerns related to personnel matters should be reported to Human Resources.
b. Concerns related to laws and regulations should be reported to the Compliance Officer.
c. Concerns related to financial misconduct, inappropriate expenditure of funds, questionable internal controls or accounting practices, and conflicts of interest should be reported to Internal Audit.
d. Concerns related to safety or security should be reported to Security Office.
e. Concerns related to academic activity should be reported to the Office of the Provost.
4. Employees who wish to remain anonymous may make reports using the Confidential Report Line.
a. Lewis-Clark State College uses Lighthouse Services, Inc. ethics and compliance hotline services.
b. Reports can be made 24 hours a day, 7 days a week through the telephone or website.
c. Employees making reports will be given the opportunity to receive follow-up on their concern.
d. Reports will be routed from Lighthouse Services, Inc. to the applicable Lewis-Clark State College department(s) for review.
5. Lewis-Clark State College will review every report made to the Confidential Report Line.
a. The department(s) receiving the report from Lighthouse Services will gather evidence through initial inquiries to determine if an unethical or illegal activity has occurred and if it should be further investigated.
b. The department(s) will determine what other appropriate Lewis-Clark department(s) or employee(s) need to be involved to fully investigate violations.
c. Administration will be notified when appropriate.
d. Investigations will be performed timely, discreetly and confidentially. Records will be examined and additional inquiries through employee interviews will be made as necessary.
e. The investigating department(s) will issue a final written report to applicable management.
f. Internal Audit will follow up with the department involved about implementing changes in procedures to avoid future violations.
g. There is a possibility the investigation may identify the employee making the report in the effort of obtaining a complete account of relevant and necessary facts.
6. Employees shall not be subject to reprisal or retaliation for raising genuine concerns and making reports in good faith.
a. Employees who believe they have been retaliated against for making a report should immediately contact Human Resources.
b. An immediate investigation will be performed.