Whistle-blowing

WU is committed to the highest standards of legal, ethical and moral behavior. No person should be personally disadvantaged for reporting a wrongdoing. WU is committed to maintaining a supportive work-relationship environment where legitimate concerns can be reported without fear of retaliation, retribution or disadvantage. It applies to WU board members, employees, contractors and consultants.

Definitions are as follows:

• Whistleblowing is the disclosure by or for a witness, of actual or suspected wrongdoing in an organization that reveals fraud, corruption, illegal activities, gross mismanagement, malpractice or any other serious wrongdoing.
• A whistle-blower is a person who reports serious wrongdoing in accordance with this policy.
• Wrongdoingincludes conduct that is fraudulent, corrupt or illegal, or any activity that breaches state or federal legislation. It may include, but is not limited to, financial wrongdoing, including circumvention of internal controls or violation of the accounting policies. It also includes unethical behavior that may breach WU’s code of conduct or other ethical statements.

A person considering making a whistle-blower report is obliged to act in good faith, have reasonable grounds for believing the disclosure is reportable wrongdoing, and provide relevant information.

Whistle-blowers must report as soon as possible in writing or orally. They may report to either the president, or their head of department, depending on the nature of the suspected wrongdoing. Reports may be anonymous, although the obligation to report is not satisfied by the individual reporting his or her own violation anonymously.

WU will endeavor to protect the confidentiality of a whistle-blower’s identity and whistleblowing reports, and will also take reasonable precautions to store any records relating to a report of wrongdoing securely, and to permit access only by authorized persons. WU will take all reasonable steps to prevent retaliation against any whistle-blower unless the report is intentionally false and/or malicious.

Any breach of this policy can result in disciplinary action, including termination.