Whistleblower Protection Policy

Responsible Unit: CEIS | Executive lead: President
Created: 2011 | Revised: 11/4/2019, 01/29/2022, 04/22/2023 | Effective: 04/22/2023
Compliance: 41 USC 4712, NWCCU 2.D.2, 2.F.1
Approving Body: BOT
Classification: Institution-wide

Policy:  
PNWU expects members of the PNWU community (employees, students, volunteers, trustees, contractors, and vendors) to comply with all federal and state laws and regulations as well as University policies. PNWU also expect members of the PNWU community to report any violations of such laws, regulations, or policies and other University related misconduct they witness or have good reason to believe occurred. A supervisor or a University official shall not compel or otherwise coerce any member of the PNWU community to violate a law or University policy. Thus, PNWU is committed to protecting individuals who make a protected disclosure or refuse to follow an illegal instruction. 

Protected disclosures may be made on a confidential basis or may be submitted anonymously using the electronic confidential reporting form. Protected disclosures and investigatory records are kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. 

Employees of contractors, grantees, subcontractors, and subgrantees, when working on Federal grants and contracts in connection with the University, have certain whistleblower rights and remedies afforded by statute, including but not limited to 41 U.S.C. 4712. Accordingly, all such contractors, grantees, subcontractors, and subgrantees are required to comply with all applicable laws. 

No PNWU community member shall take retaliatory action against any individual for reporting, or causing to be reported, suspected wrongful conduct, or for assisting in an authorized investigation of alleged wrongful conduct. Retaliation, if confirmed, will result in disciplinary action. 

Persons who believe they have been subjected to retaliation in violation of this policy should notify Compliance, Ethics, and Integrity Services; Human Resources; Student Affairs; or the Provost’s Office. 

An individual who knowingly or with reckless regard for the truth gives false information or knowingly makes a false report of wrongful conduct or a subsequent false report of retaliation is not protected under this policy and will be subject to disciplinary action, up to and including termination or expulsion. The fact that an allegation is not substantiated will not result in corrective action if it is made in in good faith. 

PNWU will exercise its authority to take whatever action may be needed to prevent and correct activities found to constitute wrongful conduct. 

Definitions: 
Protected disclosure is a communication about suspected wrongful conduct engaged in by a University employee, student, volunteer, agent, or contractor (who is not also the disclosing individual) based in fact on a good faith and reasonable belief that the conduct has both occurred and is wrongful under applicable law and/or University policy. 

Retaliation means adverse action against an individual, including but not limited to harassment and/or adverse employment consequences, because the individual made a protected disclosure or participated in an investigation, proceeding or hearing involving a protected disclosure. 

Whistleblower is a term used to describe a person who exposes any kind of information or activity deemed illegal, or unethical within an organization. 

Wrongful conduct is any action or omission taken by or within the University that is illegal, fraudulent, or in violation of University policies, procedures, or Code of Conduct. Wrongful conduct includes, but is not limited to, violations of law including fraud; unauthorized use of University property or resources; fraudulent or dishonest financial reporting, bribery, or kickbacks; and research or other academic fraud. 

Procedure: 
N/A 

Related documents: 
Reporting Suspected Wrongful Conduct Policy and Procedure/Form 
Progressive Discipline Policy 

Policy Resources

For assistance with policies and procedures contact:

Lori Fulton
lfulton@pnwu.edu