Part III: Recursive Policy
Rob Schlink, JSI’s VP for Contracts and Compliance, responded to concerns I raised around transparency and due process (see his August 23 email) by claiming that JSI was following its “standard investigation process,” and that I should look to JSI’s Employee Handbook and Code of Conduct to find my answers. So I did.
JSI’s Code of Conduct does not include any details on how claims like mine are investigated, or how conflicts of interest are handled within that process. The Employee Handbook dedicates two pages to describing its “Harassment/Discrimination/Grievance Procedure.” Those pages can be found here, but the relevant language is copied here:
[T]he Policy Administrator, after reporting the incident to the Director of Human Resources will undertake the initial investigation, and attempt to identify a satisfactory solution. Should a resolution satisfactory to all parties be found, the incident will be closed. If these initial measures are not sufficient to resolve the concern, the case will be further reviewed by JSI/Boston Human Resources, in order to arrive at a satisfactory resolution.
Bold red formatting was added by me to denote positions which are held by Laura Colantropo (Policy Administrator / Boston HR Lead / Director of Human Resources), who previously wrote that she “didn’t see a conflict of interest” in leading an investigation in which she was also a subject.
Is this how JSI’s policies and procedures are supposed to work? At the time, I felt that these policies and procedures, and their interpretation by senior JSI leaders, prioritized protecting the institution above ensuring a fair and transparent investigation.
• • •
I hope it’s clear that I’m not writing to advocate for myself—I’ve already lost my job and have given up hope that OIG’s investigation will ever be conducted. The reason I’m writing, then, is best explained toward the end of my first blog in this series:
Things like this don’t get better until people start sharing their stories, so my silver lining is that I get to do just that and, hopefully, contribute to making things a little better for those who come after me (especially my students).
Given what I have shared above, and in previous posts, I’m concerned that JSI does not have the policies and procedures in place to ensure due process and prevent conflicts of interest when they investigate claims of fraud and misconduct. It honestly doesn’t matter if my concerns were valid—they were raised in good faith and, in my experience, the policies, procedures, and people required to support a fair and transparent investigation all failed.
Given my personal experience, I believe there are serious questions worth asking about whether JSI has the safeguards in place to appropriately protect those who raise concerns about ethics, fraud, misconduct, and compliance.
—
This blog post reflects my personal experiences and opinions. It is based on my recollection of events and the information available to me at the time of writing. While I strive for accuracy, if any individual or organization believes a factual statement is incorrect, I welcome the opportunity to address and, if necessary, correct the record. Please contact me directly with any concerns, and I will promptly review and consider corrections in good faith.