Office of Origin: Human Resources; Finance
Responsibility: Chief Financial Officer
Original Date Adopted: 4-27-10
Dates Reviewed: 1-15-12, 5-5-18, 7-13-18, 1-12-22 (C)
Last Date Board Approved: 8-28-18

Lake Michigan College (the College), including its trustees, officers, and all employees, has an obligation and commitment to conduct all affairs of the College in accordance with the highest standards of integrity and ethics, and in compliance with applicable Federal and State laws and College policies.

In order to promote this commitment, the College is adopting this policy governing the reporting of allegations of improper or illegal conduct (hereafter “misconduct”), including the protection from retaliation of persons making such allegations and/or cooperating in an investigation of such allegations.

This policy applies to all trustees, officers, and employees including part-time and student employees (the “employees”).

It is the policy of the College to investigate any suspicion or allegation of employee misconduct, fraud involving accounts or operations and significant violation of policies or procedures. The College will conduct these investigations in a manner that protects the civil rights of those who may be the subject of allegations.

An employee who makes a good faith disclosure of information that may evidence misconduct, such as a violation of law policy, or other wrongful conduct should not be subjected to any adverse employment action or retaliation based on the disclosure. However, an employee who knowingly makes a false allegation, or whose allegations are not made in good faith, is not protected under this policy, and will be subject to appropriate discipline An employee may also be the subject to discipline or an adverse personnel action for reasons unrelated to making a report.

Employees who become aware of significant misconduct have an obligation to report to the Chief Financial Officer (CFO),  Executive Director of Human Resources, or other Cabinet member as soon as possible, but no later than 1 year after becoming aware of the alleged misconduct. This includes any suspected theft, fraud, embezzlement, destruction of property, or other wrongdoing causing a loss to the College.

An employee who receives a report of misconduct must advise the CFO and/or the Executive Director of Human Resources of the allegation of misconduct and the resolution, if any, of the allegation. Records of all such allegations will be maintained by Human Resources.

In the event that a report of misconduct involves the CFO and/or the Executive Director of Human Resources, the report should be made to the President.

Employees must cooperate with an investigation into an allegation of misconduct. Employees’ responsibilities include, but are not limited to, responding to auditors and/or investigators truthfully and supplying requested information and documents without fabrication, destruction, omission, or alteration.

An employee should provide as much detail as is available when reporting misconduct. A report should be made in writing by the employee making the complaint. The College will maintain the confidentiality of the employee reporting the misconduct to the extent practical. However, the College cannot guarantee confidentiality, and the identity of the person making a complaint may become known. 

The College will determine the appropriate course of action to be taken upon receipt of an allegation of misconduct. Anonymous reports and non-specific, broad, or unsubstantiated allegations lacking evidentiary support will not be investigated.

An employee who violates this policy may be subject to disciplinary action, up to and including termination.

References: Michigan Whistleblower’s Protection Act: MCL 15.362 et seq.