Policy for Whistleblowing Procedures
Approved by Board of Trustee Financial Affairs Committee
Effective May 7, 2007
Section 301 (m)(4) of Sarbanes-Oxley Act of 2002 (“SOX”) requires MidAmerica Nazarene University (MNU) to have in place a policy regarding concerns of questionable accounting or auditing matters. MNU is committed to high ethical standards in all activities associated with the university. In the matters of the accounting department there are no exceptions. It is important that the university maintains the confidence of faculty, staff, students and families, donors, vendors, Church of the Nazarene constituents, and the public in the quality of accounting and public reporting. Under the Sarbanes-Oxley Act of 2002, the Financial Affairs Committee of the Board of Trustees is responsible for the receipt, retention, and treatment of complaints received by MNU regarding accounting, internal accounting controls or auditing matters. The Financial Affairs Committee is additionally responsible for the confidential, anonymous submission by MNU employees (faculty, staff, student workers and administrators) of concerns regarding questionable accounting or auditing matters.
Procedures:
Reporting: MidAmerica Nazarene University’s policy will be published on MNU’s web site and handbook. Any employee may submit an accounting/auditing complaint by following the procedures listed:
a. Accounting/auditing complaints may be made by any of the following methods:
By email to Leland King, Financial Affairs Committee Chair at lelandking@everestkc.net
By letter addressed to Accounting Complaint, Financial Affairs Committee, c/o MidAmerica Nazarene University, 2030 E College Way, Olathe, KS 66062. Your letter will be unopened and forwarded to Leland King.
b. Any person submitting an accounting/auditing complaint is encouraged to provide as much information as possible regarding the subject matter of the complaint. Resolution of the problem will rely on the integrity of the information provided. The more details provided, the more the complaint can be investigated and addressed.
c. The employee communicating an accounting/auditing complaint does not need to identify himself/herself. An anonymous complaint will not result in any attempt to identify the employee making the allegation. Due to the nature of allegations, anonymous complaints will not be taken lightly; anonymous complaints will be subject to preliminary analysis before an investigation proceeds. All accounting/auditing complaints submitted by employees will be treated confidentially. If the employee does identify himself/herself, their identity will not be disclosed without their permission unless required by law to do so. No employee will be subject to retaliation because of an accounting/auditing complaint made in good faith. In the event an employee knowingly makes false allegations, their conduct will result in disciplinary action.
d. The Financial Affairs Committee Chair will report on the nature of all accounting complaints received since the prior committee meeting. In the event the chairperson determines a complaint is severe in nature and requires an evaluation by the committee prior to the next regularly scheduled meeting, the chairperson shall contact the other members of the Financial Affairs Committee to determine how to proceed.
Investigation: The Financial Affairs Committee Chair or committee members (depending on the severity and potential impact of complaint) will take appropriate steps considered necessary to investigate any accounting/auditing complaint. Upon the outcome of the investigation, the chairperson or committee members will propose to the Vice President of Finance or Board of Trustees (which ever is appropriate), a solution to resolve any deficiency or error properly identified in an accounting/auditing complaint, and may retain advisors to assist in carrying out any investigation and proposing any solution.
Implementation: The Financial Affairs Committee is responsible for the implementation of this Policy and the provisions outlined herein. It may interpret the Policy and make judgments about the application of the procedures. It may request reports from any office with accounting and/or auditing functions about the implementation of this policy and take any action necessary to implement the policy. The Financial Affairs Committee may amend this Policy at its discretion.
