To facilitate CWI’s commitment to oversight, strong internal controls and clear fiscal procedures in its business functions by providing guidance regarding CWI’s expectations of its employees in the conduct of CWI’s business.
This policy applies to all administration and employees of CWI.
Conflict of Interest: Any official action or any decision or recommendation by a person acting in a capacity as a public official, the effect of which would be to the private pecuniary benefit of the person or a member of the person's household, or a business with which the person or a member of the person's household is associated.
Fraud: A false representation of a matter of fact, whether by words or by conduct, by false or misleading representations, or by concealment of what should have been disclosed, that deceives or is intended to deceive another so that the individual will act upon it to her or his legal injury.
The purpose of CWI’s business ethics policy is to provide guidance to its employees and departments in the conduct of business, both internally and with the general public. Ethics are the rules, standards, or code of conduct that govern our decisions on a daily basis. The business ethics policy establishes the proper environment of internal controls, fiscal responsibility and clear procedures so that CWI conducts its business functions in an ethical manner.
CWI requires all employees to act in accordance with all federal, state and local laws and regulations. Employees are expected to be of high moral character and utilize judgment to avoid the appearance of impropriety.
CWI shall maintain proper business policies and best practices to meet fiscal objectives in an ethical framework. Oversight shall include but not be limited to the following:
CWI’s administration, employees and students are prohibited from engaging in any activities that may be considered to be fraudulent under federal, state or local law. Employees are required to report known or suspected fraudulent activity; including prohibited activity by vendors, contractors or consultants.
Violations of any of CWI’s business procedures, or instances of fraud, misappropriation or fiscal irregularity by any employee will be brought to the immediate attention of the Administration. Examples of such violations include, but are not limited to the following:
External independent auditors may be brought in to investigate any issue at the discretion of the President or the Board. Interference with a review or investigation of ethics violation or fraud is prohibited and is also subject to disciplinary action. Interference includes, but is not limited to, failing to cooperate with auditors or investigators, and the destruction, alteration, or removal of documentation relating to the review or investigation.
Although employees reporting possible violations of this policy in good faith are protected by CWI’s whistleblower policy, employees may choose to remain anonymous when making a report. Therefore, CWI has established a hotline to serve as an additional mechanism to report suspected compliance violations. ()
CWI takes all reports regarding ethics and compliance matters seriously and will investigate each report. Employees may submit a report about a compliance or ethics concern or ask for guidance related to a compliance or ethics matter. The information provided via CWI’s Hotline may be relayed to CWI in a format that protects the employee’s anonymity.
Employees who violate this policy may be subject to disciplinary action up to and including termination and possible restitution.