This Whistleblower Policy (Policy) of the Association of American Veterinary Medical Colleges (AAVMC) requires directors, officers and employees to observe high standards of business and personal ethics in connection with the conduct of their duties and responsibilities at AAVMC. As employees and representatives of the AAVMC, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.  In that regard, the Policy of AAVMC: (1) encourages individuals to come forward with credible information on illegal practices or serious violations of adopted policies of the Association; (2) specifies that the Association will protect the person from retaliation; and (3) identifies where such information can be reported.

 

Encouragement of reporting.  The Association encourages complaints, reports or inquiries about illegal practices or serious violations of the Association’s policies, including illegal, improper or unethical conduct by the Association itself, by its leadership, or by others on its behalf.  Appropriate subjects to raise under this policy would include financial improprieties, accounting or audit matters, ethical violations, or other similar illegal, improper or unethical practices or policies.  Other subjects on which the Association has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment via the Association’s human resources channels, unless those channels are themselves implicated in the wrongdoing.  This policy is not intended to provide a means of appeal from outcomes in those other mechanisms.

 

Protection from retaliation.  The Association prohibits retaliation by or on behalf of the Association against directors, officers, or employees of AAVMC for making good faith complaints, reports, or inquiries under this policy or for participating in a review or investigation or responding to inquiries under this policy. This protection extends to those whose allegations are made in good faith but prove to be mistaken. The Association reserves the right to discipline persons who, upon review and/or investigation, it determines made bad faith, knowingly false, or vexatious complaints, reports, or inquiries or who otherwise abuse this policy.

 

Where to report.  Complaints, reports or inquiries may be made under this policy on a confidential or anonymous basis. They should describe in detail the specific facts demonstrating the basis for the complaints, reports or inquiries.  They should be directed to their supervisor, the Association’s Executive Director, or the Association’s President; if all of those persons are implicated in the complaint, report, or inquiry, it should be directed to the Association’s Immediate Past-President or to anyone in management whom the employee feels comfortable in making the complaint, report or inquiry. The Association’s officers, supervisors, managers are required to report suspected ethics violations to the Association’s Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when employees are not satisfied or uncomfortable with reporting to a supervisor, manager, or the officers identified here, individuals should contact the Association Compliance Officer directly. The Association, through the Compliance Officer, or others as directed by the Board of Directors, will conduct a prompt, discreet, and objective review or investigation. Individuals must recognize that the Association may be unable to fully evaluate a vague or general complaint, report, or inquiry that is made anonymously.

 

Compliance Officer.  AAVMC’s Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at the Compliance Officer’s discretion, shall advise the Executive Director and/or the finance committee. The Compliance Officer has direct access to the finance committee of the board of directors and is required to report to the finance committee at least annually on compliance activity.