Whistleblower Policy

For those visitors who have not yet seen the letter we received from Vicar General Richard Erikson and our proposed response, please take a moment to read that before checking out today’s post.

Today we visit the issue of a “whistleblower policy” first mentioned in Open Letter of several weeks ago.  This has been recommended by archdiocesan auditors for several years now, but the recommendation has apparently been ignored or not acted on in any visible way–kind of like the concerns raised in this blog and by faithful Catholics and clergy for years.  Since we first posted the idea, several archdiocesan audit aficionados (ie people from the outside audit firm and others who love the pursuit of auditing but prefer to remain anonymous about it) have shared the specific recommendation made to the archdiocese.  We have also heard from people expert in this area who pointed us to the publicly accessible policies that other dioceses have in place.  We share this for your knowledge and edification, and to also hopefully stop the discrediting of this anonymous blog by the archdiocese.

Anonymous Submission Process Recommended by Auditors to Boston Archdiocese

  • Currently, the [Archdiocese] does not have an anonymous submission process where employee or donor concerns are able to be communicated to the [Finance Council/Archbishop/Boards of Directors].
  • We recommend the implementation of an anonymous submission process where employee or donor concerns can be voiced directly to the [Finance Council/Archbishop/Board of Directors].
That is the recommendation.  We did not make this up.  This is not new.  Explicit in a whistleblower policy is that there is no risk of retaliation, and either explicit or implicit in such a policy is an actual framework and commitment that someone with authority will promptly investigate the claim and act on it if the claim is found valid. Here are two examples from other dioceses:

Archdiocese of Indianapolis:

In “Whistleblower Policy: How to Report Suspicions of Misuse of Funds and Property” they state that they “highly encourage and would be grateful for any information regarding the misuse or the potential for future loss of funds or property…If you suspect misuse of funds or property but do not have complete proof, we would still appreciate any information you could share.”  They use a 3rd party hotline service, called EthicsPoint, and commit anonymity, that every claim will be investigated, and that a report will be provided afterwards to every individual who makes a report and provides contact information.  We do not recall seeing this same spirit of appreciation and openness in the statements from the Archdiocese of Boston regarding this blog, but will reread them in case we missed that.
Here is the Archdiocese of Indianapolis’ “Non-Retaliation” policy:
Non-Retaliation
The parishes, schools, agencies, and other entities of the Archdiocese sincerely appreciate reports that are made and will not retaliate or take action against any person who makes a report. For employees, they will not suffer a loss of employment, a decrease in wages, or other adverse consequences due to making a report. For other individuals (volunteers, parishioners, parents, clients of programs, etc.) who make reports, the Archdiocese will make every effort to protect their identities and their interests.
Diocese of Charlotte

In their Code of Ethics Policy of the Diocese of Charlotte, they open witha list of 15 principles of ethics and integrity including the following:
  • Church Personnel will conduct themselves at all times in a manner that is consistent with the teachings and precepts of the Roman Catholic Church.
  • Church Personnel will exhibit the highest Christian ethical standards and personal integrity.
  • Church Personnel will continually and objectively examine their own actions and intentions to ensure that their behavior promotes the welfare of the diocese and exemplifies the moral tradition of the Church.
  • Church Personnel will be responsible stewards of diocesan resources, human and financial, observing both canon and civil law
  • Church Personnel will share concerns about suspicions of inappropriate behavior with the appropriate supervisory or management individual.
  • Accountability: The Diocese and all its parishes, schools and organizations are responsible to its stakeholders, which includes donors and others who have placed their trust in the Church. To uphold this trust, all Church personnel will: Promote good stewardship of all Church resources, including donations, grants, program fees, and all financial support….Use all Church resources in a prudent-like manner, avoiding unnecessary and excessive spending and wastefulness.
There is a 16-point list on Conflicts of Interest.  16 points.  See section 6.1
Conflicts of Interest: A conflict of interest may exist when persons employed by the diocese (i.e., the Central Administration, parishes, schools, agencies, and/or affiliated entities), or volunteers with influence over certain activities or transactions including those serving on advisory or consultative boards, councils or committees have a direct or indirect financial interest, as defined below.

Financial Interest: A person has a “financial interest” if the person has, directly or indirectly, through business, investment, or family (including
spouses; brothers or sisters; spouses of brothers or sisters; ancestors; children, grandchildren, and great grandchildren; and spouses of
children, grandchildren, and great grandchildren), any one of the following:

  • An ownership or investment interest in any entity with which the diocese has a transaction or arrangement;
  • A compensation arrangement with the diocese or with any entity or individual with whom the diocese has a transaction or arrangement;
  • A potential ownership or investment interest with, or compensation arrangement with, any entity or individual with
  • whom the diocese is negotiating a transaction or arrangement.
  • Compensation includes direct and indirect remuneration as well as gifts or favors that are substantial in nature.
Church Personnel are to avoid situations that might present a conflict of interest.
Here’s an excerpt from their Whistleblower policy (Section 8):
The objectives of the Whistleblower Policy are to establish policies and procedures for:
  • The submission of concerns regarding questionable financial or legal matters, violations and suspected violations of the Code of
  • Conduct, Code of Canon Law and other concerns by the stakeholders of the Church, on a confidential basis;
  • The receipt, retention, and treatment of complaints received by the Diocese of Charlotte
  • The protection of anyone reporting concerns from retaliatory actions.

Reporting Responsibility – Each representative of the diocese has an obligation to report in accordance with this Whistleblower Policy any reasonably perceived violation of: (a) federal, state or local laws, rules and/or regulations; (b) the diocese’s Code of Ethics; (c) the diocesan sexual misconduct policy; (d) diocesan personnel policies; (e) diocesan financial policies, including questionable or improper accounting or auditing matters; as well as gross mismanagement, waste, fraud, embezzlement, neglect of duty; and actions that threaten or are viewed as harmful to the health, safety and welfare of others and any other financial, legal or canonical concerns (hereinafter collectively referred to as Concerns).

Investigation – The person to whom said report was made shall be responsible for a thorough and expeditious investigation of the reported Concern.

No Retaliation – This Whistleblower Policy is intended to encourage and enable stakeholders to raise Concerns within the Organization for investigation and appropriate action. With this goal in mind, no stakeholder who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. Moreover, anyone who retaliates against someone who has reported a Concern in good faith is subject to discipline up to and including dismissal from their position within the Church.

Confidentiality – Reports of Concerns, and investigations pertaining thereto, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

So there we have several examples.  We do not know about other people reading this blog, but frankly we are starting to get fed up with the Boston Archdiocese’s lack of response to fundamental issues like this and the ones we have documented.

ps. Silence Meter Update:

  • 18 days passed since posting of August 23 Open Letter, with no response to the specific points raised in the letter
  • 49 days passed since July 23 email to archdiocese asking for explanation of conflicts of interest that led to hiring Communications Secretary and Chancellor; no response.
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2 Responses to Whistleblower Policy

  1. [...] and acted upon without fear or risk of retaliation.  We raised this in detail in our posts Whistleblower Policy and Whistleblower Policy: Part 2 last September.  We are pleased to report there has been [...]

  2. Michael says:

    A whistleblower policy that:
    a. no one has ever written down,
    b. no one has ever seen,
    c. no one has ever heard of,
    d. no one has ever been notified of its existence,
    e. no one has ever used to actually blow the whistle on anyone else,
    f. no one has ever been kept safe from retaliation for having blown such a whistle, and,
    g. pursuant to which (in the brief history of its non-existent existence) it has exposed not one ounce of corruption in the Archdiocese.

    … is all you really need to know isn’t it? The best laid plans of mice and Cardinals …

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