Whistleblower Policy (Ethics Hotline)

G1.25 Whistleblower Policy (Ethics Hotline)

To communicate adherence to university’s policies and procedures and to encourage good faith reports of allegations of misconduct concerning compliance with university policies and procedures.

The university expects its employees (faculty, staff and students) to perform their duties and responsibilities in accordance with university policies and procedures. The university provides various mechanisms to assist and encourage employees to come forward in good faith with reports or concerns about suspected compliance issues. Employees may report suspected non-compliance issues without fear of reprisal or retaliation. Diligent efforts will be made to protect the complainant from retaliation for his/her activities in cooperation with, or initiation of, an inquiry or investigation, provided the complaint is not undertaken in bad faith.

1. An employee should follow all university policies and procedures in carrying out his/her duties and responsibilities for the university.
2. An employee, who has a question about the propriety of any practice under university policies and procedures, should seek guidance from his/her supervisor or the university official who has responsibility for overseeing compliance with the particular policy or procedure.
3. An employee, who becomes aware of a potential or actual material violation of university policies and procedures, should report such potential or actual conduct, regardless of whether the employee is personally involved in the matter.
4. An employee may request that such a report be handled anonymously or as confidentially as possible under the circumstances, and the university will endeavor to handle all such reports with discretion and with due regard for the privacy of the reporting employee.
5. An employee may make anonymous reports, with the understanding that any investigation may identify the employee in order to obtain a full and complete account of relevant and necessary facts from the employee or to ask additional questions or seek clarification as any investigation proceeds.
6. An Employee who comes forward in good faith with reports or concerns about compliance with university policies or procedures shall not be subject to reprisal or retaliation for making such a report. Any employee who believes that he/she is being retaliated against for making such a report should immediately bring it to the attention of his/her dean or the Provost’s Office (for academic employee) or to the Office of Human Resources (for staff employees) for immediate investigation.
7. An employee is encouraged to make such a report to his/her immediate supervisor. If the employee feels unable to do so or if there is any reason why this matter may not be appropriate, the employee should raise the issue with his/her manager, department chair, dean, director or the university office or official who has responsibility for overseeing compliance with the particular policy or procedure in accordance with the guidelines below. An employee who is unsure to whom he/she should make a report or address his/her concerns should consult with the Office of Human Resources or the Compliance Officer.
   • In the event of any claim of financial misconduct or inappropriate expenditure(s) of funds (including all grant funds, federal and non-federal), or any claim regarding questionable internal controls, accounting practices or auditing matters, the employee should follow the guidelines above, but should also make such a report to the Chief Financial Officer and to the Internal Auditor.
   • In the event of a concern about personnel issues, the employee should follow the guidelines above, but should also make such a report to the Office of Human Resources.
   • An employee with reports or concerns about the university’s non-discrimination policy is encouraged to consult with the university’s Equal Opportunity officer.
   • An employee with reports or concerns about sexual harassment is encouraged to consult with the university’s Equal Opportunity Officer.
   • An employee with reports or concerns about conflict of interest should consult with his/her supervisor, department chair or director, but, in the case of questions concerning such supervisory personnel, the employee should also feel free to consult with the dean, or university officer who is responsible for the unit.
   • An employee with reports or concerns about workplace safety issues is encouraged to consult the University Safety department.
   • An employee with reports or concerns about environmental or hazardous materials/hazardous waste issues is encouraged to consult with the university’s Environmental Management Office.
   • An employee with reports or concerns about academic fraud or research misconduct should consult with the Provost or the Associate Provost.
   • An employee who is unsure to whom he/she should make a report or address his/her concerns should consult with the Human Resource office or the Compliance Officer.

8. If individuals are uncomfortable discussing concerns with a university official, the university has developed the Ethics Portal to collect allegations anonymously. Reports can be made 24 hours a day/7 days a week. All reports are routed directly to the Office of Internal Audit and Risk Management and the Division of Legal Affairs and Compliance for review and directed to the appropriate institutional official(s).

   A non-exhaustive list of unethical or illegal behavior might include:

   1. Shortcomings in regulatory compliance
   2. Theft of university assets for personal benefit
   3. Inappropriate relationships with employees, customers, or vendors.
   4. Excessive gift(s) from a vendor
   5. Sexual harassment of or discrimination against an employee or student
   6. Falsification of time sheets or university records
   7. Research Misconduct
   8. Information Security Breach
   9. Misuse of sponsored research funds
   10. Bribes or kickbacks
   11. Purchase of personal items with university funds
   12. Improper financial reporting
   13. Questionable accounting/auditing

   Initial reports to the hotline call center are submitted to an appropriate university contact within the Office of Internal Audit and Risk Management, for follow-up and possible investigation. These contacts may include officials from the offices listed above.

   Employees who report conduct that they believe is illegal or unethical should have a reasonable factual basis for believing that improper activities have occurred, and should include as much specific information as possible to allow for proper assessment of the nature, extent, and urgency of the incident.

   Individuals may contact the university's anonymous reporting option via the internet at Ethics Portal. 

9. The university will review every report to the hotline. An investigation will be conducted if a review establishes that the allegation constitutes unethical or illegal activity, and if it is supported by specific information, or corroborating evidence. Departments within the university that have responsibility for conducting investigations include: Internal Audit and Risk Management, Human Resources, Institutional Equity and Compliance, Research Administration, Office of the General Counsel, and Financial Services.

   Other departments may become involved in investigations based on their areas of oversight responsibility or expertise.

   Efforts will be made to perform investigations discreetly. The details of the investigation will be kept confidential, to the extent feasible, and consistent with university policies and applicable federal, state, and local laws. The university is committed to conducting an appropriate and timely response to each report submitted through the hotline, as well as appropriate and timely closure to those allegations which proceed to the investigation process.