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Reporting Improper Conduct (Policy on)

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Policy Information
  • Issue Date: October 12, 2006
  • Revision Date: July 5, 2012
  • Primary Contact: Vice President for Legal Affairs and General Counsel Administration
  • Senior Administration: President and Director and the Vice President for Finance and Chief Financial Officer
  • Responsible Office: President and Director
Policy Statement
The Woods Hole Oceanographic Institution expects its staff or other personnel affiliated with the Institution to uphold high standards of business and personal ethics in the conduct of research, education or other Institution business. The Institution finds intolerable any action or conduct that compromises these high standards. Additionally, WHOI is committed to maintaining a workplace where personnel are free to raise concerns regarding the Institution’s practices. Specifically, it is the policy of Woods Hole Oceanographic Institution that any employee, postdoc, student, applicant, contractor, vendor or other party affiliated with the Institution shall be free of fear of retaliation for bringing forward good faith allegations of misconduct when the individual reasonably believes there may be evidence of financial malfeasance, legal compliance issues, practices that may expose individuals to public health and/or safety dangers, or practices that may violate WHOI policies.

Reason for Policy
The Sarbanes-Oxley Act of 2002 (the Act) was signed into law in July 2002. The Act calls for greater accountability for business leaders in light of corporate failures such as Enron and WorldCom. Although at this point non-profits are not covered by Sarbanes-Oxley, the Institution supports the philosophical goals of the Act and therefore requires all directors, officers, employees, postdocs and students to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. This policy guides individuals as to the appropriate action to take if they reasonably believe ethical or legal standards have been or may have been breached.

Policy Information
Policy Statement
Reason for Policy
Who Should Be Familiar With This Policy
Related Documents
Definitions & Responsibilities
   Improper Conduct
   Financial Malfeasance
   Individual making a Report
   Audit Committee
   Raising Concerns
   Actions to be taken

Who Should Be Familiar With This Policy
  • Directors
  • Vice Presidents
  • Employees
  • Students
  • Postdocs
  • Other individuals who have a relationship with the Institution that relate to the Institution’s business (e.g. Trustees, Corporation members, contractors, vendors, guest investigators, customers, etc.)

Related Documents
Institution Policies
Other Documents
Environmental, Health & Safety Policy
Conflict of Interest Policy
Grievance Policy  
Policy Against Harassment  
Policy on Scientific Misconduct  
Privacy Policy  
Respectful Workplace and Violence Prevention Policy  


If you have questions about specific issues or need assistance with the interpretation of this policy, contact:

President and Director   x2500
V.P. for Finance and CFO   x2325
Director of Human Resources   x2705

Definitions & Responsibilities
These definitions apply to these terms as they are used in this policy.

Improper Conduct For purposes of this policy, “improper conduct” means one of the following: (1) illegal conduct, (2) an act or omission causing a substantial risk to public health or safety to members of Institution community and/or a neighboring community, (3) violation of an Institution policy that does not have its own procedure for reporting and investigating alleged violations, or (4) financial malfeasance. The Policy on Scientific Misconduct and the Policy Against Harassment are examples of policies that include procedures for reporting and investigating violations. Reports about inappropriate conduct that is not within the scope of this definition of “improper conduct” are not subject to this policy.
Financial Malfeasance For purposes of this policy “financial malfeasance” means wrongful conduct involving Institution financial resources. It does not include expenditures based on policy choices or other expenditures that the responsible official reasonably and in good faith believes are in the Institution’s interests, nor does it include disputes about de minimis amounts.
Individual making a Report A person who reports to an appropriate person at the Institution or the WHOI Ethics Hotline on what he/she reasonably believes to be improper conduct, as defined in this policy. Such individuals may be employees, postdocs, students, applicants, vendors, contractors or the general public. The role of the individual making the report is simply as a reporting party and does not include any investigatory or fact finding responsibilities, nor does the individual making the report determine any appropriate corrective actions that may be warranted.
Retaliation Includes harassment, intimidation, adverse employment or academic actions, or any other tangible form of retaliation, against individuals who reasonably makes reports of improper conduct in accordance with this policy or who cooperate in good faith in inquiries or investigations under this policy.
Audit Committee Under the Bylaws of the Woods Hole Oceanographic Institution, the committee that “assists the Trustees in discharging their fiduciary responsibilities by providing an independent review of the adequacy of financial condition of the Institution and of the adequacy of the financial controls and financial reporting. The Audit Committee and its authorized representatives shall have full access to the books and records of the Corporation as necessary for the performance of its duties.”


The Institution recognizes the importance of reporting improper conduct at the earliest possible stage to ensure a healthy and productive work environment. The Institution must provide the means of ensuring that anyone can confidentially raise issues of concern about improper conduct without fear of retaliation. The Institution expressly prohibits any form of retaliation, including harassment, intimidation, adverse employment or academic actions, or any other tangible form of retaliation, against individuals who reasonably makes reports of improper conduct in accordance with this policy or who cooperate in good faith in inquiries or investigations under this policy.

An individual’s action of making a report of improper conduct will be protected by this policy if the individual has:

  1. Followed the procedures set forth below
  2. Acted reasonably and in good faith and not for personal gain or for personal motives
  3. Reasonably believed that the information disclosed under these procedures indicated improper conduct as defined above.

Raising Concerns An individual who wishes to report suspected improper conduct may do so by following the normal chain of command. In most cases, the employee’s supervisor or student’s advisor will be in the best position to address the concern. If, for whatever reason, the individual is not comfortable discussing the issue with the supervisor/advisor or, if having done so, is not satisfied with the supervisor/advisor’s response, the concern can be reported in writing to either the Vice President for Finance and Chief Financial Officer or the Director of Human Resources. In the event the concern relates to the Vice President for Finance and Chief Financial Officer and/or the Director of Human Resources, it may be reported to the President and Director.

In any case, the identity of the individual making the report will be maintained in confidence to the extent that is consistent with conducting an appropriate inquiry as determined by the Institution.

In situations where an individual prefers to place an anonymous report in confidence, they are encouraged to use the WHOI Ethics Hotline, hosted by a third party hotline provider, EthicsPoint.

 WHOI Ethics Hotline: 1-866-868-0920


The information provided through the WHOI Ethics Hotline noted above will be shared with the Institution’s EEO Officer/Title IX Coordinator by EthicsPoint on a completely confidential and anonymous basis. Unless the individual allows differently, personal contact information will not be shared. Means of communication between individuals filing a report and the Institution will be facilitated entirely through EthicsPoint.

Anyone reporting suspected improper conduct must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of law or WHOI policy. However, any allegations that are unsubstantiated and that were made maliciously or that were made with knowledge that they were false will be viewed as serious disciplinary offenses.

The protections of this policy apply only to the extent that an allegation is made under this policy. For example, publicizing an allegation is not protected conduct, since publicity, particularly of an unsubstantiated allegation, may cause unwarranted harm to an individual’s reputation.

Actions to be taken

The Vice President for Finance and Chief Financial Officer or Audit Committee, as appropriate and with consultation with any or all of the contacts listed in this policy, will have discretion over the nature of the inquiry and/or investigation regarding the concern raised. If the concern or complaint is with regard to corporate accounting practices, internal controls or auditing, the Vice President for Finance and Chief Financial Officer will immediately notify the Audit Committee and will work with the Committee until the matter is resolved. Where considered appropriate an internal or external audit will begin. The police will be involved if there is evidence of criminal activity.

If the concern or complaint is with regard to scientific misconduct as defined by the Policy on Scientific Misconduct, sexual or other discriminatory harassment in violation of the Policy Against Harassment, or a violation of any other policy that has a reporting and investigation process, that policy shall apply and this policy shall not.

Follow-up Following an inquiry and/or investigation, within the bounds of the Institution’s Privacy Policy and to the extent practical, the individual who made the report will be informed of the outcome of the inquiry or investigation.

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Last updated: June 12, 2017

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