Whistleblower Policy

Our Lady of Good Counsel High School , Inc. (“OLGCHS”) accepts and investigates allegations of improper violations of OLGCHS’s code of ethics or suspected violations of laws or regulations that govern OLGCHS operations (“Violations”) by OLGCHS employees or where OLGCHS is potentially a victim of wrongdoing.

Because we do not undertake investigations without adequate cause, we need as much evidence as possible to corroborate the allegation(s) such as documents, witnesses, and other specific and relevant information. Investigating Violations is more difficult if complaints are filed anonymously because of the difficulty of obtaining evidence to corroborate the alleged improper activity before we begin an investigation. If you choose to file your complaint anonymously, be sure to provide specific and relevant information including the first and last names of any individuals mentioned, their contact information, and the location address at which the improper activity occurred.

When describing the Violation, please provide as much of the following information for each of your allegations and number each allegation, if there is more than one.

  • Who? Who is involved? If outside businesses or contractors are involved, what are the names of the businesses, who owns them, and where are they located? Who else knows about the improper activities? Who can and would confirm that they occurred? How can we reach these witnesses?
  • What? What specifically did the suspect do? What is wrong with it? Are there laws or regulations that govern what the suspect did? What kinds of documents would provide evidence of the improper activities? Where are the documents located? Who controls them?
  • Where? Which division, unit, or campus location did the action happen? When? When did the improper activity occur? Is it ongoing? How frequently has it occurred?
  • Why? What are the suspect(s) motives? For example, how does the suspect benefit? If others benefit from the activities, who are they and how do they benefit?
  • How? How did the wrongdoing occur? Was there a lack of controls, circumvention of controls, or collusion with other individuals?

Instructions | Whistleblower Report

Application

This Whistleblower Protection Policy applies to all of Our Lady of Good Counsel High School, Inc.’s (“Good Counsel” or “School”) staff, whether full-time, part-time, or temporary employees, to all volunteers, to all who provide contract services, and to all officers and directors, each of whom shall be entitled to protection.

Good Counsel requires its employees and representatives to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Good Counsel, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

No Retaliation Policy

It is contrary to the values of Good Counsel for anyone to take action against any board member, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Good Counsel. No person entitled to protection shall be subjected to retaliation, intimidation, harassment, or other adverse action for reporting information in accordance with this Policy. Any person entitled to protection who believes that he or she is the subject of any form of retaliation for such participation should immediately report the same as a violation of and in accordance with this Policy. Any individual within Good Counsel who retaliates against another individual who has reported a Violation in good faith or who, in good faith, has cooperated in the investigation of a Violation is subject to discipline, including termination of employment or volunteer status.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Good Counsel can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Good Counsel’s code of ethics or suspected violations of law or regulations that govern Good Counsel’s operations. A protected person shall be encouraged to report information relating to illegal practices or violations of policies of Good Counsel (a “Violation”) that such person in good faith has reasonable cause to believe is credible.

Reporting Procedures

Good Counsel has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the President. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Good Counsel’s President, who has the responsibility to investigate promptly all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the President. Information shall be reported to the President, unless the report relates to the President, in which case the report shall be made to the Chair of the Board of Directors who shall be responsible to provide an alternative procedure.

Compliance Officer

The School’s Compliance Officer is the President. The Compliance Officer will advise the Chair of the Board of Directors of all complaints and their resolution.

Accounting and Auditing Matters

Good Counsel’s President shall immediately notify the Audit Committee/Finance Committee of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved. The President will report in writing at least annually to the Board’s Executive Committees on compliance activity relating to accounting or alleged financial improprieties.

Confidentiality

Good Counsel encourages anyone reporting a Violation to identify himself or herself when making a report in order to facilitate the investigation of the Violation. However, reports may be submitted anonymously by:

1) Completing the online form below; or

2) Downloading a Whistleblower Report Form, completing the report and mailing the form in an envelope marked “Confidential” to: Dr. Paul G. Barker, Ed.D., Compliance Officer for Whistleblower Matters, Our Lady of Good Counsel High School, 17301 Old Vic Blvd., Olney, MD 20832.

*Please note: If you would prefer not to submit a report directly to the President's Office, forms can be mailed to the attention of the Board of Directors Chair, c/o Our Lady of Good Counsel High School.

Reports of Violations or suspected Violations will be kept confidential to the extent possible, with the understanding that confidentiality may not be maintained where identification is required by law or in order to enable Good Counsel or law enforcement to conduct an adequate investigation.

Dissemination and Implementation of Policy

This Policy shall be disseminated in writing to all affected constituencies. Good Counsel shall adopt procedures for implementation of this Policy, which include:

(1) Documenting reported Violations;

(2) Working with legal counsel to decide whether the reported Violation requires review by the Compliance Officer or should be directed to another person or department;

(3) Keeping the Board of Directors informed of the progress of the investigation;

(4) Interviewing employees;

(5) Requesting and reviewing relevant documents, and/or requesting that an auditor or counsel investigate the complaint; and

(6) Preparing a written record of the reported violation and its disposition, to be retained for a specified period of time.

The procedures for implementation of this Policy shall include a process for communicating with a complainant about the status of the complaint, to the extent that the complainant’s identity is disclosed, and to the extent consistent with any privacy or confidentiality limitations.

SUBMIT REPORT

Whistleblower Report

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