Reporting Ethical Misconduct and Non-Retaliation Policy
|Approved by:||Board of Trustees|
|History:||Issued -- July 21, 2011|
|Revised -- September 6, 2016|
|Related Policies:||Code of Conduct|
|Additional References:||Compliance and Ethics Helpline tel. (855) 350-9396, www.thecatholicuniversityofamerica.ethicspoint.com|
|Responsible Official:||Chief Ethics and Compliance Officer and Chief Privacy Officer tel. (202) 319-6170|
I. Policy Statement
The Catholic University of America is committed to conducting its affairs ethically and in compliance with laws, regulations, and University policies. To promote a culture of ethics and compliance, suspected unethical conduct must be brought to the attention of University officials when there is a good faith belief that the conduct has occurred. Ethical misconduct may include non-compliance with a law, University policy, the University Code of Conduct, or other standard or requirement applicable to the University.
Retaliation against members of the University community for making good faith reports is strictly prohibited, and is subject to disciplinary action up to and including termination.
II. Reporting Ethical Misconduct
Individuals normally should report ethical misconduct to their supervisors. If an individual is uncomfortable speaking with a supervisor, the report may be made to the department responsible for the law, regulation, or subject area. Individuals also may make a report directly to the Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU
Individuals who are not comfortable using the foregoing reporting channels may make a report anonymously through The Catholic University of America’s Compliance and Ethics Helpline (toll free at tel. (855) 350-9396, or online at www.thecatholicuniversityofamerica.ethicspoint.com. The Helpline is administered by a third party vendor (not the University). All reports are forwarded to the Chief Ethics and Compliance Officer for investigation from the third party vendor, and are investigated per University procedure.
III. Retaliation Prohibited
It is prohibited to discharge, demote, suspend, threaten, harass, intimidate or otherwise retaliate against an individual in the terms or conditions of employment or educational opportunity based on:
• An individual’s good faith report of ethical misconduct, or the good faith report of another person made on that individual’s behalf;
• An individual’s cooperation with an investigation or other proceeding regarding a report of potential ethical misconduct; or
• An individual’s refusal to engage in any practice that violates laws, regulations or University policies if the individual has identified the alleged violation to the department, unit or individual responsible for compliance with that law, regulation or policy.
Retaliation is prohibited regardless of whether the underlying matter ultimately is substantiated.
Individuals who believe they have been subjected to retaliation should report the conduct to the Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU or through the Compliance and Ethics Helpline (toll free at tel. (855) 350-9396 or online at www.thecatholicuniversityofamerica.ethicspoint.com. The Chief Ethics and Compliance Officer will investigate all reports of alleged retaliation.