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POLICY NUMBER: HR.022
EFFECTIVE DATE: 07/27/25
APPROVAL DATE: 07/27/25
PURPOSE: The purpose of this policy is to establish a clear process for reporting, investigating, and addressing suspected improper activities within Life University, while protecting individuals from retaliation for making good faith disclosures.
SCOPE: This policy applies to all members of the Life University community. All employees (Staff & Faculty) and Students of Life University
APPROVAL AUTHORITY: President
RESPONSIBLE AUTHORITY: HR, Finance
ADDITIONAL AUTHORITY: N/A
RECIPIENTS: N/A
PUBLICATIONS: Employee Handbook
DEFINITIONS:
Improper Activities: The following constitute a non-exclusive list of improper activities:
- Fraudulent or Dishonest Conduct - A deliberate act or failure to act with the intention of obtaining anunauthorized benefit from the University. Examples of such conduct include, without limitation:
- Forgery or alteration of any documents
- Unauthorized alteration or manipulation of computer files
- Fraudulent financial reporting
- Pursuit of a benefit or advantage in violation of the University’s Conflict of Interest Policy
- Misappropriation or misuse of University resources, including funds, supplies, or other assets
- Authorization or receipt of compensation for services not received or not performed, or hours not worked; and
- Violations of law.
Whistleblower: An individual who informs a supervisor/department head, Executive Vice President and Provost, Vice President or the relevant Dean, or the Chair of the Audit/Finance Committee, about any potential improper activities.
Baseless Allegations: Allegations made with knowledge of or reckless disregard for the truth.
POLICY TITLE
Whistleblower Policy
POLICY STATEMENT
Life University (“the University”) has a responsibility for the stewardship of its resources and the private support that enables it to pursue its mission. The Board and administration are committed to compliance with the laws and regulations to which the University is subject and to promulgating University policies and procedures to interpret and apply these laws and regulations in the University setting. The University’s internal controls and operating procedures are intended to detect and to prevent or deter fraudulent or dishonest conduct, and/or violations of law (referred to hereinafter as “improper activities”). However, even the best systems of control cannot provide absolute safeguards against improper activities. Intentional and unintentional improper activities may occur. The University has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities and to report the actions taken by the University. The University will investigate any alleged improper activities and may discipline any individual found to have engaged in such conduct, up to and including dismissal from the University. The University reserves the right to refer such conduct for civil and criminal prosecution.
All members of the University community are encouraged to report possible improper activities. Employees (including student employees) should report concerns to their supervisor/department head. Students not working for the University should report their concerns to the supervisor/department head of the University employee whom they believe to be engaging in such improper activity. University supervisors and department heads are required to report any concerns brought to them, and any situations in which they suspect improper activities, to their Executive Vice President and Provost, Vice President or the relevant Dean. If, for any reason, an individual finds it difficult to report his/her concerns to the relevant supervisor/department head, he/she may report the matter to the relevant Executive Vice President and Provost, Vice President or the relevant Dean, or directly to the Chair of the Audit/Finance Committee of the Board of Trustees (“the Audit/Finance Committee”), in the manner set forth in the procedures below
PROCEDURE(S)
Supervisors/Department Heads are required to notify their Executive Vice President and Provost, Vice President or the relevant Dean of reports/concerns of suspected improper activities.
Supervisors/Department Heads should take reasonable care in dealing with allegations of improper activities to avoid:
- Baseless allegations
- Premature notice to persons suspected of improper activities and/or disclosure of such suspected conduct to others not involved in the investigation
- Violations of whistleblower protection
Accordingly, a supervisor/department head who is informed of suspected improper activities should NOT contact the person suspected and should NOT discuss the matter with anyone other than the Executive Vice President and Provost, Vice President, Dean or General Counsel.
Once the Executive Vice President and Provost, Vice President or the relevant Dean is aware of any suspected improper activities, he/she will assess the allegations to see that they are not baseless and will then conduct an investigation (or direct that an investigation be conducted), reach a conclusion on whether the improper activity occurred, and proceed to take whatever action, including disciplinary measures, he/she deems appropriate. In handling reports, the Executive Vice President and Provost, Vice President or the relevant Dean may consult with appropriate persons, but should not disclose such suspected conduct to those not involved in the investigation or who do not have a need to know.
The General Counsel will serve as a resource to the Executive Vice President and Provost, Vice President or the relevant Dean throughout the investigation and handling of the matter. The Executive Vice President and Provost, Vice President or the relevant Dean will prepare a report summarizing the suspected improper activity, the investigation, the conclusion, and the actions taken, and General Counsel will retain such record for the purpose of documenting resolution of reported alleged improper activity. If General Counsel, upon review of the summary report, believes that the matter has not been sufficiently addressed, General Counsel may forward the matter to the Chair of the Audit/Finance Committee of the Board of Trustees for review. General Counsel will provide a status report of all complaints and their disposition under this policy to the Audit/Finance Committee at its regular meetings. If the Executive Vice President and Provost, Vice President or the relevant Dean, upon receipt of a report of improper activity, for any reason feels uncomfortable handling the matter, he/she may forward the report to the Chair of the Audit/Finance Committee and request that the Audit/Finance Committee review, investigate (as appropriate) and resolve the matter. If, for any reason, an individual feels uncomfortable using the reporting mechanisms set forth above and wishes to make a report of improper activity directly to the Audit/Finance Committee, he/she may do so in writing in a sealed envelope addressed to the Chair of the Audit/Finance Committee or General Counsel’s Office, Midtown Proscenium, Suite 2200, 1170 Peachtree Street, N.E.Atlanta, GA 30309- 7200 (sealed envelopes sent to General Counsel’s Office will be delivered intact to the Chair of the Audit/Finance Committee for evaluation). General Counsel will serve as a resource to the Audit/Finance Committee in its review, investigation (as appropriate), and resolution of any reported misconduct under this policy. A record of all complaints/reports made under this policy will be maintained by General Counsel for the purpose of documenting resolution.
RIGHTS AND RESPONSIBILITIES
The University and its employees may not retaliate against a whistleblower with the intent or effect of adversely affecting the terms and conditions of employment (including, without limitation, threats of physical harm, loss of job, punitive work assignments, impact on salary or wage).
A whistleblower who believes that he/she has been retaliated against may file a written complaint in a sealed envelope addressed to the Chair of the Audit/Finance Committee or General Counsel’s Office, Midtown Proscenium, Suite 2200, 1170 Peachtree Street, N.E.Atlanta, GA 30309-7200 (sealed envelopes will be delivered intact to the Chair of the Audit/Finance Committee).
OTHER NOTES
N/A
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