OAK LAWN PUBLIC LIBRARY
BOARD POLICY
WHISTLE-BLOWER GUIDELINES AND PROTECTIONS
Overview
The Oak Lawn Public Library (OLPL) is committed to the highest standards of ethical, moral and business conduct and of openness and accountability. This whistle-blower policy creates a mechanism whereby, if a trustee, director, department head, manager, staff member, volunteer, vendor or other stakeholder becomes aware of a violation of a policy or law, such violation can be reported without a fear of retaliation. The OLPL can help protect the Library as well as its trustees, director, department heads, managers, staff members, volunteers, vendors or other stakeholders by ensuring that all are aware of this policy and fully understand how to report their concerns with assurances that they will be protected from reprisals or victimization for whistleblowing.
OLPL will investigate complaints of suspected fraudulent or dishonest use or misuse of its resources or property by staff, elected officials, appointed officials, consultants, vendors, independent contractors, or volunteers. To maintain the highest levels of service,
OLPL will also investigate complaints concerning its programs and services.
It is the policy of OLPL to maintain an environment and culture in which individuals may report and testify about OLPL actions involving suspected fraudulent or dishonest use or misuse of its resources or property which are illegal or that violate specific public policies, and do so without retaliation.
OLPL policies require that trustees, volunteers, and employees observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of the OLPL must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
The objectives of the Whistle-Blower Policy are to establish policies and procedures for the following:
- The submission of concerns regarding questionable ethical, legal, accounting or audit matters by trustees, directors, department heads, managers, staff, volunteers, and other stakeholders of the OLPL, on a confidential and anonymous basis
- The receipt, retention, and treatment of complaints received by the OLPL regarding ethical, legal, accounting, internal controls, or auditing matters
- The protection of trustees, volunteers, and employees reporting concerns from retaliatory actions.
Reporting Responsibility
Each trustee, director, department head, manager, staff member, volunteer, vendor and other stakeholders of the OLPL have an obligation and are required to report, as soon as practicable, in accordance with this whistle-blower policy allegations of (a) questionable or improper accounting or auditing matters, incorrect or fictitious financial reporting, asset misappropriation, procurement irregularities, corruption and influence and (b) violations and suspected violations of OLPL policies, laws, local ordinances and other activities that amount to serious instances of improper conduct or ethical matters.
Acting in Good Faith
Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a digression from the high standards of the OLPL and constitute a cause for action as set forth in the paragraph above. Although the person reporting the concern is not expected to prove the truth of an allegation, that person should be able to demonstrate to the person contacted that the report is being made in good faith. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense. It may also result in discipline, up to and including dismissal from the volunteer position or termination of employment or the termination of a vendor or independent contractor relationship. Such conduct may also give rise to other actions, including civil lawsuits.
Confidentiality
Reports of concerns, and investigation pertaining thereto, shall be kept confidential to the extent possible, consistent with the law and the need to conduct an adequate investigation. In the interest of maintaining such confidentiality, such reports are to be made in accordance with the processes detailed in this policy and not during the public comment session of any meeting of the OLPL Board of Trustees.
Disclosure of reports of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment or the termination of a vendor or independent contractor relationship. Such conduct may also give rise to other actions, including civil lawsuits.
Authority of President of the OLPL Board of Trustees
All reported concerns (not involving the President of the OLPL Board of Trustees) will be forwarded to the President of the OLPL Board of Trustees in accordance with the procedures set forth herein. The President of the OLPL Board of Trustees shall be responsible for investigating and making appropriate recommendations to the Board of Trustees, with respect to all reported concerns. The President and OLPL Board of Trustees will have final authority on matters pertaining to this policy.
No Retaliation
This whistle-blower policy is intended to encourage and enable trustees, volunteers, employees, vendors and other stakeholders to raise concerns within the OLPL for investigation and appropriate action. With this goal in mind, no trustee, director, department head, manager, staff member, volunteer, vendor or other stakeholders who, in good faith, reports a concern shall be subject to retaliation or, in the case of a director, department head, manager or staff member adverse employment consequences. Moreover, any volunteer or employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.
This Policy protects all OLPL employees, officers, contractors, subcontractors, and agents of the organization from discharge, demotion, suspension, threats, harassment, or any discriminatory or retaliatory activity against the individual because of revealing information in the following situations:
a) Providing information or assisting in an investigation regarding any conduct that the individual reasonably believes constitutes fraud or violates regulations set forth by any federal, state, or local regulatory or law enforcement agency, or any person with supervisory authority over the employee of OLPL.
b) Filing, testifying, participating in, or assisting in a proceeding filed or about to be filed against the OLPL relating to an alleged violation of fraud laws or regulations.
Individuals who feel they are being retaliated against due to the submission of any type of complaint that is covered by this Policy may file complaints with the appropriate federal or state regulatory agency within 90 days following the date of the alleged retaliation. The agencies can be reached by mail or phone:
U.S. Department of Labor
200 Constitution Ave, NW
Washington, DC 20210
1-866-4-USA-DOL
Illinois Department of Labor
160 North LaSalle, Suite C-1300
Chicago, Illinois 60601
(312) 793-2800
Any violation of this Policy will result in discipline up to and including discharge or termination of contract in the case of an independent contractor or vendor. Any violation of this Policy that also constitutes a violation of law may result in criminal penalties and civil liabilities for the offending employee.
Reporting Concerns
Encouragement of Reporting
This policy is designed to enable any trustee, director, department head, manager, staff member, volunteer, vendor or other stakeholder the ability to raise concerns internally or at a higher level, if appropriate, which an individual believes constitutes fraudulent or unethical behavior or any form of an impropriety that may put the OLPL at risk. This policy is intended to cover concerns which are in the public interest and may be investigated and lead to further action by the OLPL Board of Trustees or specific disciplinary or other measures.
The OLPL encourages complaints, reports, or inquiries about unethical, illegal practices or serious violations of its policies including illegal or improper conduct by the OLPL 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, asset misappropriation, procurement irregularities, corruption and influence, ethical violations, or other similar illegal or improper practices. Other subjects on which the OLPL has existing complaint mechanisms should be addressed under those mechanisms, such as raising matters of alleged discrimination or harassment through the OLPL’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.
This policy is not intended to prevent or discourage any trustee, director, department head, manager, staff member, volunteer, vendor or other stakeholder from disclosing such information to a government or law enforcement agency. This is particularly true should the concern involve the personal safety of an individual, the security of Library property or a violation of Local, State or Federal law or any rule or regulation promulgated by such authorities. Criminal allegations may be reported locally by contacting the Oak Lawn Police Department at 708-422-8292.
Employees
Employees should first discuss their concern with their immediate supervisor or department head. If, after speaking with his or her supervisor, the individual continues to have reasonable grounds to believe the concern is valid, the individual should report the concern to the Human Resources Coordinator at 708-422-4990 x311. However, if the individual is uncomfortable speaking with his or her supervisor or department head, or the supervisor or department head is a subject of the concern, the individual should report his or her concern directly to the Human Resources Coordinator. In addition, suspected fraud or a grave concern involving a superior should be reported directly to the President of the OLPL Board of Trustees, who may be contacted by phone at 708-925-6893, by e-mail at kim.brightmore@gmail.com or by regular mail at:
Kim Brightmore, President of the OLPL Board of Trustees
4636 West 107th Street
Oak Lawn, Illinois 60453
If the concern was reported verbally to the Human Resources Coordinator, the reporting individual, with assistance from the Human Resources Coordinator, shall reduce the concern to writing. The Human Resources Coordinator is required to promptly report the concern to the President of the OLPL Board of Trustees, which has specific and exclusive responsibility to investigate all concerns. If the Human Resources Coordinator, for any reason, does not promptly forward the concern to the President of the OLPL Board of Trustees, the reporting individual should directly report the concern to the President of the OLPL Board of Trustees. If the concern involves the President of the OLPL Board of Trustees, the individual shall contact two sitting Trustees in writing.
Trustees and Volunteers
Trustees and a reporting party who is not an employee or volunteer of OLPL should submit concerns in writing directly to the President of the OLPL Board of Trustees. Volunteers should submit their concerns to the supervisor of their unit. If volunteer feels that approaching their supervisor is inappropriate, they may then discuss their concerns with their department head. If volunteer feels that approaching their department head is inappropriate, they may then report their concerns to the President of the OLPL Board of Trustees as detailed above. If the concern involves the President of the OLPL Board of Trustees, the individual shall contact two sitting Trustees in writing.
Handling of Reported Violations
The President of the OLPL Board of Trustees shall address all reported concerns brought to his or her attention. The President of the OLPL Board of Trustees shall immediately notify the members of the Board of Trustees of any such report. The President of the OLPL Board of Trustees will notify the sender and acknowledge receipt of the concern within five business days, if possible. Any concerns raised by an employee of the OLPL with their supervisor or department head must be immediately reduced to writing, signed by the individual reporting the concern and the individual receiving the report. A copy of this report shall be provided to the reporting individual. Furthermore, a written record shall be made of any and all follow-up efforts as well as the final disposition of the issue. The reporting individual must be provided with a written copy of the disposition of any reported issue within 48 hours of such disposition. Should the reporting individual then feel that the reported issue remains unresolved they may bring the issue to the attention of the President of the OLPL Board of Trustees.
All reports will be promptly investigated by the President of the OLPL Board of Trustees and one other designated member of the Board of Trustees. Appropriate corrective action will be recommended to the Board of Trustees, if warranted by the investigation. In keeping with the confidentiality requirements as detailed above, all discussion of a reported issue by the OLPL Board of Trustees will be in closed session pursuant to (5 ILCS 120/) Open Meetings Act. ILCS Exception (1) (c) Exceptions to the extent possible under the law. Final disposition of any reported issue may be in an open meeting. In addition, action taken must include a conclusion or follow-up, or both, with the complainant for complete closure of the concern.
The President of the OLPL Board of Trustees has the authority to retain outside legal counsel, accountants, private investigators, or any other resource deemed necessary to conduct a full and complete investigation of the allegations.
Adopted: 07/21/20
Revised: 08/18/20; 07/18/23, 07/15/25