EthicsPoint

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

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.

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:

• It is a streamlined and structured process.
• It can be anonymous.
• There is written intake of the report (even if reported through telephone hotline) which makes reports auditable and progress easily tracked.
• There are reporting tools to create reports for the audit committee of the board as well as reports to analyze trends;
• It allows for intake by HR for in-person reporting.
• It supports multiple languages.
• There is access 24 hours a day, 365 days a year.

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:

• Theft
• Accounting irregularities
• Conflict of interest 
• Wage/hour violations
• Data breaches
• Financial fraud
• Unsafe working conditions

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.

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.

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

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.

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.

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.

Reports are entered directly on the EthicsPoint secure 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.

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.

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.

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 …”

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.

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

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.

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.

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

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.

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

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.