The Catholic University of America

 Internal Investigations Policy

Approved by:  
History: Issued              -- January 29, 2019
  Revised            --
  Last Reviewed -- January 29, 2019
Related Policies: Code of Conduct for Staff and Faculty; Code of Student Conduct; Employee Indemnification Policy; Non-Retaliation Policy; Reporting Financial Irregularities PolicyGovernment and External Requests for Information Policy
Additional References:  
Responsible Official: Chief of Staff and Counselor to the President tel. (202) 319-5104

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 I.       Policy Statement 

The Catholic University of America is committed to conducting its affairs ethically and in compliance with laws, regulations, and University policies, and to safeguarding members of the University community and University resources. 

When a report of potential ethical misconduct or other wrongdoing is made, the University has a responsibility to investigate and implement corrective action, if necessary.  To meet this responsibility, employees of the University community must cooperate with University Investigations (defined below).    

Questions regarding the application of this policy may be directed to the Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU), or the Office of General Counsel (tel. (202) 319-45142 or CUA-OGC@CUA.EDU). 

II.       Definitions 

A.   Investigation means a University-authorized internal examination, inspection, inquiry, analysis, or review to determine facts.  An Investigation is not a hearing or legal proceeding, and may be formal or informal. Investigations may be undertaken by University units, including, but not limited to Compliance, the Office of the Dean of Students, Equal Opportunity/Title IX Coordinator, General Counsel, Human Resources, Internal Audit, and Public Safety. 

III.       Duty to Cooperate 

All employees (staff and faculty) must cooperate fully with investigations undertaken by persons charged with conducting the inquiry. Cooperation with investigations includes, but is not limited to: 

•   Promptly acknowledging and responding to requests for information; 

•   Making oneself available for meetings with investigating officials; 

•   Providing full, accurate, and truthful information; 

•   Keeping confidential information learned or transmitted during the investigation, unless directed by legal authorities, and 

•   Preserving relevant information and documents. 

Non-cooperation or obstruction of an investigation is subject to University disciplinary action, to include termination of employment. 

IV.     Confidentiality and Non-Retaliation 

Confidentiality for individuals who are interviewed or otherwise cooperate in an investigation will be maintained to the extent possible by law.  While absolute confidentiality cannot always be guaranteed, all matters will be kept private (i.e., shared only with those with a need to know). 

To protect the confidentiality of individuals who participate in investigations, and to protect the integrity of the investigative process, individuals normally will not be informed of the outcome of an investigation. 

Per the University’s Non-Retaliation Policy, retaliation based on an individual’s cooperation with an investigation is prohibited, and subject to disciplinary action.  All suspected reports of retaliation should be reported immediately to the Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU), or to the Office of General Counsel (tel. (202) 319-45142 or CUA-OGC@CUA.EDU), or other senior level personnel.