PLATTEKILL PUBLIC LIBRARY 

WHISTLEBLOWER POLICY 

 Adopted: March 12, 2015 (Plus Attachment) 

The Plattekill Public Library is committed to upholding the highest standards of ethical, moral and legal business conduct, and transparency through open communication.  Accordingly, all trustees, officers, employees and volunteers are required to comply with applicable federal, state and local laws, and must faithfully implement and adhere to the Library’s policies and procedures in conducting their duties and responsibilities. 

This policy provides an avenue for all trustees, officers, employees and volunteers to report any suspected or actual conduct contrary to these standards without the fear of intimidation, harassment, discrimination or retaliation. 

Reporting Responsibility 

DUTY TO REPORT: It is the Library’s policy that all trustees, officers, employees and volunteers of the Library have a responsibility to report known or suspected violations in accordance with this Whistleblower Policy.  This includes reporting any action or suspected action taken by or within the Library that is illegal, fraudulent or in violation of any policy of the Library; which the reporter has either actual knowledge of or has a reasonable good faith belief that same has occurred.  Suspected or wrongful action(s) regarding the Library’s finances and governance include but are not limited to the following: 

Incorrect financial reporting 

Unlawful activity 

Activities that are inconsistent with the Library’s policies 

Activities which otherwise amount to improper conduct 

Procedure 

OVERSIGHT:  The Oversight Committee of the Plattekill Public Library will consist of the Director, President of the Board of Trustees and Vice President of the Board of Trustees.  This Committee will oversee the adoption, implementation of and compliance with this Whistleblower Policy. 

COMPLIANCE OFFICER:  The Compliance Officer will be the President of the 

Board of Trustees.  Should the Compliance Officer be the subject of the report, the Oversight Committee will appoint another member of the Committee to perform the Compliance Officer’s role with regard to the allegations.  The Compliance Officer will be responsible for administering the Whistleblower policy, overseeing an investigation and reporting to the Oversight Committee.  The Compliance Officer will report to the Library’s Board of Trustees at least annually on compliance activity. 

REPORTING VIOLATIONS: All reports should be made using the Whistleblower Reporting Form, attached hereto, which will be available on the Library’s website under the Policy Section.  Trustees, officers, employees and volunteers should promptly report allegations to the Compliance Officer.  If the reporter deems it inappropriate to file the report with the Compliance Officer, the report may be submitted to the Board’s Vice President.  Any reports received by the Board’s Vice President, including the completed Whistleblower Reporting Form, shall be submitted to the Oversight Committee, subject to the restriction under the Compliance Officer section. 

ANONYMOUS REPORTING: With the exception of a person’s report of his or her own violation, the reporter will not be required to provide his or her name on the form.  However, anonymous reports must include sufficient information, including but not limited to, the name of the person against whom the report is being made, the date of the incident, and a description of the incident, so that an investigation can be made. 

HANDLING REPORTS: The Oversight Committee will provide the reporter a timely acknowledgment of receipt of the report.  All reports submitted will be placed on the agenda of a meeting of the Oversight Committee.  An appropriate investigation will be undertaken by the Oversight Committee, or legal counsel or other designee if deemed appropriate by the Oversight Committee. A report summarizing the findings will be given to the reporter within 10 days of the Oversight Committee’s meeting, if a name is provided on the Whistleblower’s 

Reporting Form.  If more than 10 business days from the date of the Oversight Committee’s meeting are needed to complete a thorough investigation, the reporter will be notified in writing of an estimated date when the investigation will be completed. 

RESULTS OF INVESTIGATION:  If the investigation establishes that a violation of law, external regulation or Plattekill Public Library policy has occurred, then the Oversight  Committee will determine the appropriate action based upon law and Library policy and make a recommendation to the Board. Civil or criminal prosecution will be pursued when warranted. If the investigation establishes that no violation of law, external regulation or Library policy has occurred, then the Oversight Committee shall report to the Board its findings and determination. The investigation is closed when the Compliance Officer has deemed the investigation is complete and the Oversight Committee has approved a recommendation for a resolution and/or corrective action to the Board.  

DOCUMENTATION: The Compliance Officer will document the investigation and explain the rationale for any recommended resolution and/or corrective action. All documentation relating to the investigation, including the Whistleblower Reporting Form, and the resolution and/or corrective action taken shall remain in the Library’s records in the Library’s Business Office and/or Oversight Committee records for at least five years. 

CONFIDENTIALITY:  All violations or suspected violations may be submitted on a confidential or anonymous basis. Reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation and prevent or correct suspected action(s). The Compliance Officer shall disclose information relating to a report with those who have a need to know so that the Oversight Committee can conduct an effective investigation and determine what action to take based on the results of any such investigation. In appropriate cases, the investigation documents will be shared with law enforcement personnel. Disclosure of reports to individuals not involved in the investigation shall be viewed as a serious disciplinary offense and may result in discipline, up to and including dismissal, termination or civil lawsuits. 

PROTECTION AGAINST RETALIATION:  Any Plattekill Public Library trustee or officer, employee or volunteer who reports a suspected or actual violation(s), in good faith shall not suffer intimidation, harassment, discrimination or other retaliation or, in the case of an employee, adverse employment action. 

Regulations  

DISCIPLINE FOR RETALIATORY CONDUCT:  Retaliation is a serious 

violation of this policy and should be reported immediately to the Plattekill Public Library Board President. Depending on the nature and seriousness of the offense, the Board will impose appropriate discipline against any trustee, officer or employee found to have engaged in any form of retaliatory conduct against an individual reporting suspected or actual wrongful action(s) in accordance with this policy, up to and including dismissal or termination, and referral to the New York State Board of Regents for possible removal of a trustee, pursuant to New York State Education Law Section 226. Volunteers that engage in any such conduct will not be permitted to volunteer in Library activities. 

GOOD FAITH REPORTING:  Any Plattekill Public Library trustee, officer, employee or volunteer who files a report concerning a violation or suspected violation must do so in good faith and have reasonable grounds for believing the information in the report indicates a violation under this policy. The Board will impose appropriate discipline against any trustee, officer or employee found to have knowingly made a report/complaint in bad faith, up to and including dismissal or termination, and referral to the New York State Board of Regents for possible removal of a trustee, pursuant to New York State Education Law section 226. This includes, but is not limited to, giving false information or making a report in retaliation. Volunteers that engage in any such conduct will not be permitted to volunteer in Library activities. 

Applicability and Distribution of Policy  

This policy will apply to and be distributed to all employees, trustees, officers, and volunteers of the Plattekill Public Library at the time of appointment or hiring and annually thereafter. 

Confidential 

The Whistleblower Reporting Form provides an avenue for all trustees, officers, employees and volunteers of the Plattekill Public Library to report actual or suspected wrongful conduct without fear of retaliation. Please refer to the Whistleblower Policy for additional information.

PLATTEKILL PUBLIC LIBRARY CONFIDENTIAL  

WHISTLEBLOWER REPORTING FORM 

Date of Report: __________________________  

I have read the Plattekill Public Library WHISTLEBLOWER POLICY.       __Yes __No 

REPORTER'S CONTACT INFORMATION:  

(Not required if being submitted anonymously.)  

PERSON AGAINST WHOM THE REPORT OF ACTUAL OR SUSPECTED WRONGFUL CONDUCT IS BEING MADE:  

(If more than one please complete additional form(s).) 

Name Position/Title 

 _____________________________________ ______________________________ 

Work Address (if applicable & known) Phone # (if known) 

 _____________________________________ ______________________________ 

 _____________________________________ ______________________________ 

WITNESS(ES) TO ACTUAL OR SUSPECTED WRONGFUL CONDUCT:  

(Attach additional sheets if necessary.) 

DESCRIPTION OF KNOWN OR SUSPECTED WRONGFUL CONDUCT: (Please 

be as specific as possible including who, what, where, when and how?)  (Attach additional sheets if necessary.) 

_______________________________________________________________________ 

_______________________________________________________________________ 

_______________________________________________________________________ _______________________________________________________________________ 

Return completed form to:  

Plattekill Public Library Board President, 2047 Rte. 32, Modena, NY 12548 

If the reporter deems it inappropriate to file the report with the Plattekill Public Library Board President, the report may be submitted to the Plattekill Public Library Board Vice President, 2047 Rte. 32, Modena, NY 12548. 

Plattekill Public Library Compliance Officer Signature 

______________________________ Date Received ______________________