Middlebury

 

What items will be covered under the system?

Issues related to Finance, Human Resources, and workplace safety.

Is the reporting really anonymous?

Yes, if reporters choose not to give their names, we will not know who submitted the report. If reporters choose, they can provide their names.

EthicsPoint

The success of Middlebury depends not only on the competence of its faculty and staff, but also on its reputation for honesty, integrity, and bias-free conduct. Middlebury has selected EthicsPoint to provide you with a simple way to anonymously and confidentially report activities that may involve unethical or otherwise inappropriate activity or behavior in violation of the institution's established policies and Code of Conduct.

The hotline is specifically designed for reporting matters of a financial nature, Human Resources related incidents, and workplace safety. Please note that harassment and discrimination should be reported using the existing policies and procedures outlined in the Handbook.

All reports submitted through EthicsPoint will be handled promptly. They will be forwarded only to Middlebury officials with a "need to know," provided that such notification will not compromise any investigation. Appropriate action will be taken following a discreet investigation. The audit committee of the Board of Trustees and the management team at Middlebury value your input and encourage employees and other involved parties to bring serious issues and concerns to Middlebury’s attention, as well as make inquiries in good faith about potential breaches of Middlebury's Code of Conduct.

Middlebury expects any report of a violation will be made in good faith, and that it will reflect a real and legitimate concern that you believe should be addressed.

We ask that you retain your report key and password and return to this website or call back the hotline within five business days of filing a report to check for comments or follow-up questions.

What is our current ethics reporting system? How is EthicsPoint superior to what we have in place currently?

The current system is to report a violation to your supervisor or your VP or Human Resources. For finance issues the report is expected to go to the Controller.  For safety issues, the report is expected to go to the Director of Business Services.

EthicsPoint is superior because: (1) it is a streamlined and structured process; (2) it can be anonymous; (3) there is written intake of the report (even if reported through telephone hotline) which makes reports auditable and progress easily tracked; (4) there are reporting tools to create reports for the audit committee of the board as well as reports to analyze trends; (5) it allows for intake by HR for in-person reporting; (6) it supports multiple languages; and (7) there is access 24 hours a day, 365 days a year.

What is EthicsPoint and why do we need it?

EthicsPoint is a comprehensive and confidential reporting tool to assist managers and employees to work together to address fraud, abuse, and other misconduct in the workplace.

Offering our employees, parents/students, suppliers, service providers, and other stakeholders a way to report conduct that may be in violation with our stated code of conduct, helps to foster a culture of integrity and compliance and protects our reputation. As the first company to offer integrated telephone- and Web-based anonymous hotline reporting services, EthicsPoint provides individuals at all levels with the tools and information necessary to receive, investigate, report, and analyze all identified issues.

The EthicsPoint Hotline is designed to enable our employees and other stakeholders to report any issue or instance of misconduct easily and in confidence. And unlike some whistleblower hotlines that simply address incidents of major financial malfeasance, the flexibility of the EthicsPoint system enables us to capture various risks to Middlebury, including:

  1. Theft
  2. Accounting irregularities
  3. Conflict of interest 
  4. Wage/hour violations
  5. Data breaches
  6. Financial fraud
  7. Unsafe working conditions

Who is EthicsPoint?

EthicsPoint was founded in 1999 by a group of certified fraud examiners who envisioned combining the use of the Internet with their real-world expertise in fraud awareness and investigations. The initial release of the EthicsPoint solution revolutionized incident reporting with a fully integrated telephone- and Web-based “hotline” mechanism, and secure, immediate delivery of reported issues and concerns using Web-portal technology.

Will this cover our Schools Abroad, Summer Programs, and the Monterey Institute of International Studies (MIIS)?

Yes. All languages spoken at our summer programs, schools abroad, and MIIS are supported by EthicsPoint, which also has an international data center that supports European Union Data Privacy Laws.

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to file a confidential, anonymous report via either the telephone or the Internet.

What type of situations should I report?

The EthicsPoint system is designed for employees to report any violation of our stated Code of Conduct, or other concerns you may have. The EthicsPoint Reporting System is designed for reporting matters of a financial nature, as wells as Human Resources related incidents, and issues related to workplace safety.
Harassment and discrimination should be reported using the existing policies and procedures outlined in the College Handbook.

If I see a violation, shouldn't I just report it to my supervisor, a VP, or Human Resources and let them deal with it?

When you observe some behavior that you believe violates our Code of Conduct, we expect you to report it.  We recognize that you may not be comfortable reporting the issue in person.  It is for such circumstances that we have partnered with EthicsPoint.  We would rather you report anonymously than keep the information to yourself.

Does the administration really want me to report?

We certainly do. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the institution and our community.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPointsecure server. EthicsPoint makes these reports available only to specific individuals within the institution who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports confidential.

It is my understanding that any report I send from a Middlebury computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as a report originator?

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. In fact, EthicsPoint is contractually committed not to pursue a reporter’s identity.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside your work environment (such as one located at an Internet café, at a friend’s house, etc.) through the EthicsPoint secure website. Many people choose this option, as EthicsPoint’s data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that reports are completely anonymous.  Plus, EthicsPoint is contractually committed not to pursue a reporter’s identity. 

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system is designed to protect your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, avoid providing clues to your identity, such as “From my office next to Jan Smith …” or “In my 33 years at Middlebury …”

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint website. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

There is a section in the report for identifying yourself, if you wish.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Middlebury is committed to promoting ethical behavior. Unethical conduct, at any level, ultimately hurts Middlebury and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a seemingly harmless lapse in ethics can have on an otherwise healthy organization. So if you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of Middlebury policy, or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. EthicsPoint can help you prepare and file your report so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked because you weren't sure.

What if my supervisor is involved in a violation?

The EthicsPoint report distribution is designed so that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if Middlebury has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a Middlebury representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer any Middlebury questions. You and Middlebury now have entered into an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the library, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline at 866-593-6965, 24 hours a day, 365 days a year.

How do I learn more about EthicsPoint?