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Wentworth Institute of Technology (the Institute) is committed to proper accounting and financial conduct, and compliance with all applicable laws, statutes and regulations.  All officers, faculty, staff, employees, consultants, students and parents of the Institute should feel safe to report without fear of reprisal any concerns that are reasonable and made in good faith relating to the Institute’s accounting and/or financial conduct, and/or violations of law, statutes or regulations.  It is a violation of this policy for anyone, acting on behalf of the Institute, to retaliate against an individual who in good faith reports a possible violation of this policy.

This policy is not intended and may not be used for personal or employment grievances, general compensation and benefit complaints, opinions on policy, etc. Complaints that are otherwise covered by other Institute policies or procedures intended to address the matters complained of, such as (by way of example only) the Sexual Harassment Policy and Nondiscrimination Policy, are not covered by this policy, which does not replace them, and such concerns will continue to be addressed in accordance with the procedures set forth in those other policies or procedures. If it is unclear under which policy a complaint should be made, the matter should be reviewed with the Vice President for Human Resources for clarification.

As part of its commitment to financial accountability and legal conduct, the Institute expects its employees, consultants and constituents to bring to the attention of Wentworth’s senior management any concerns about the Institute’s accounting and/or financial conduct, and/or violations of law, statutes or regulations, or about known or reasonably suspected violations of this policy. Such complaints include, but are not limited to, suspected improper accounting, internal accounting controls or auditing. Complaints should be made according to the following procedure:

Notification

Whom to Notify – Individuals with a complaint or knowledge of a complaint should promptly notify the Institute. The following people should be contacted:

Brian Burns
Director of Compliance and Risk Management
Wentworth Institute of Technology
550 Huntington Avenue
Boston, MA 02115
Phone: 617-989-4413
Fax: 617-989-4168
Email: burnsb2@wit.edu

If the complaint concerns the Executive Affairs office individuals may contact:

Brian Burns
Director of Compliance and Risk Management
Wentworth Institute of Technology
550 Huntington Avenue
Boston, MA 02115
Phone: 617-989-4413
Fax: 617-989-4168
Email: burnsb2@wit.edu

Confidential and anonymous reports can always be made through the Wentworth Institute of Technology Compliance Hotline:

EthicsPoint
To make a web based report: wit.ethicspoint.com
Or Dial 855-353-9143
toll-free, within the United States, Guam, Puerto Rico and Canada

An individual with a concern may instead contact the Institute’s independent auditor:

Michael Burns, CPA
Mayer Hoffman McCann P.C.
500 Boylston Street, 4th Floor
Boston, MA 02116
Phone: 617-761-0584
Fax: 617-761-0601
Email: mburns@cbiztofias.com

Anyone receiving notification within the scope of this policy shall, as appropriate, immediately report such receipt to the Chair of the Audit Committee, who will in turn report, as appropriate, to the Board of Trustees.

Because failure to report criminal activity can itself be understood to condone the crime, individuals should come forward with information about any such activity, without regard for the identity or position of the suspected offender. Failure to report knowledge of wrongdoing may result in disciplinary action against those who fail to report.

Form of Notice – The notification should specify in reasonable detail the nature of the complaint and the persons involved in and with knowledge of the violation. It should be accompanied by any supporting documentation. Notification should be made in writing, including email, so as to promote a clear understanding of the issues raised, but also may be made orally. Notifications which are in writing may be made anonymously.

Investigation and Confidentiality

The Institute will investigate reports of violations, and all those involved are required to cooperate with such investigations. An investigation may in some circumstances mean that the Institute cannot promise complete confidentiality, but it will act as discreetly as reasonably possible, providing information to individuals on a “need to know” basis. When the Institute completes its investigation, and if it concludes that there is a problem, it will promptly take corrective action. The Institute will report on its actions to the person having made the report.

Prohibition Against Retaliation

The Institute will not discriminate against or discharge individuals for their reasonable, good faith allegations or participation in any investigation, or their reasonable, good faith efforts to ensure the Institute’s compliance with law, and it will strongly discipline anyone who threatens or retaliates against such individuals. Such prohibited retaliation includes, but is not limited to, termination, demotion, suspension, harassment, failure to consider for promotion, or any other kind of discrimination. Individuals should act reasonably and in good faith during any complaint and investigation process.

Acting in Good Faith

A person filing a complaint concerning a violation or suspected violation of this policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the policy. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Effective May 1, 2008
Revised October 15th, 2019