(Whistleblower Policy)  

Approved by Board of Trustees:  April 22, 2005

A.  Gonzaga University has a responsibility for the stewardship of university resources and the public and private support that enables it to pursue its mission.  Gonzaga University is committed to compliance with the laws and regulations to which it is subject and to promulgating university policies and procedures to interpret and apply these laws and regulations in Gonzaga University setting.  Laws, regulations, policies, and procedures strengthen and promote ethical practices and ethical treatment of all members of the Gonzaga community, those who conduct business with Gonzaga, and those who conduct Gonzaga's business.

B.  Gonzaga's internal controls and operating procedures are intended to detect and prevent or deter improper use of university assets, misappropriations, or improper commercial business transactions or activities.  However, even the best systems of control cannot provide absolute safeguards against such irregularities.  Intentional and unintentional violations of laws, regulations, policies, and procedures may occur and may constitute improper use of university assets, misappropriations, or improper commercial business transactions or activities.  Gonzaga has a responsibility to investigate and report to appropriate parties allegations of any such suspected improper activities.  Examples of improper activities are set forth in Exhibit A.

C.  Anyone may report an allegation of improper use of university assets, misappropriations, or improper commercial business transactions or activities.  A whistleblower report must be made to Gonzaga's corporate counsel and the audit committee, who may require a written statement.  The corporation counsel shall investigate to determine the facts.  The investigation shall include an opportunity for any person against whom allegations have been reported to make a report of the facts to the corporation counsel and the audit committee.  In all instances, Gonzaga retains the prerogative to determine when circumstances warrant an investigation and, in conformity with this policy and applicable laws and regulations, the appropriate investigative process and/or disciplinary process to be employed.  At the conclusion of any investigation, the corporation counsel shall make a report to the president. 

D.  This policy will be published in the Gonzaga University Faculty Handbook and in the Gonzaga University Personnel Policies and Procedures Manual.  Additionally, all Gonzaga purchase orders and contracts, to the extent possible, will contain language informing the reader of this policy and where it may be obtained.

E.  A person or entity reporting improper use of university assets, misappropriations, or improper commercial business transactions or activities is commonly referred to as a whistleblower.  Whistleblowers may be university employees (academic or staff), applicants for employment, students, vendors, contractors, or the general public.  The whistleblower's role is as a reporting party.  Whistleblowers are not investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.