TAP No. 7: Ethics Violations and Misconduct Reporting


Scope

This policy applies to all University employees.

Purpose

The purpose of this policy is to establish the consequences of fiscal misconduct and the proper reporting mechanisms to be used for notification of known or suspected fiscal misconduct.

I. Overview

Duquesne University has a responsibility for the stewardship of its resources and the public and private support that enables it to pursue its mission. The University is committed to compliance with the laws and regulations to which it is subject and to promulgating University policies and procedures to interpret and apply them in the University setting. Laws, regulations, policies and procedures strengthen and promote ethical practices and ethical treatment of the members of the University community and those who conduct business with the University.

The University has in place a system of internal controls and operating procedures that are intended to detect and prevent or deter improper activities. However, even the best systems of internal control cannot provide absolute safeguards against waste, fraud, abuse and other irregularities.

II. Business Ethics and Conduct

Each member of the University community is expected to exhibit a high degree of professionalism and personal integrity. Accordingly, employees must:

  1. Conduct all University business in accordance with the University's mission, values, established policies and procedures and applicable federal, state and local laws;
  2. Respect and not violate the privacy and/or confidentiality of information entrusted to them;
  3. Avoid conflicts of interest, be honest, and reject attempted bribery or other inappropriate coercion; and
  4. Report any information of possible violation of these requirements.

III. Reporting Suspected Violations and Confidentiality

To report a suspected violation of laws, regulations, this Policy or other University Policies and Procedures, employees are encouraged to do one of the following:

  1. Report to Management:

    Violations may be reported initially through standard management channels, beginning with the immediate supervisor. If for any reason it is not appropriate to report suspected violations to the immediate supervisor (e.g., the suspected violation is by the supervisor) individuals may go to a higher level of management within their school or division.
  2. Other Reporting Options for Violations Related to Mismanagement of University Resources:

    To the extent that reporting suspected violations to management is not feasible or appropriate, the University has established two additional reporting methods by which violations may be reported in a confidential and anonymous manner:
    1. Violations may be reported via the web at http://www.ethicspoint.com. This site is operated independently of the University to help ensure user confidentiality and, if desired, anonymity.
    2. Violations may be reported via the University's ethics reporting hotline by calling toll-free 1-866-294-8662. This hotline is also operated independently of the University to help ensure confidentiality and, if desired, anonymity.

All reports of suspected violations may be made confidentially and, if desired, even anonymously, although the more information provided, the easier it is to investigate the reports.

IV. University Response

The University is committed to investigating and taking necessary corrective actions for all suspected violations that are reported. All complaints of suspected violations will be confidentially reported to at least two appropriate senior University officials for investigation and resolution.

  1. In order to protect the integrity of the investigative process, in no instance will a University official who is specifically named in the complaint conduct the investigation and resolution.
  2. Upon completing all necessary investigations and resolutions, the University will provide routine reports of proven violations to the Board of Directors.

V. Related Information

TAP No. 30 - Alleged discrimination should be reported to the University's Director of Anti-Discrimination Policy and Compliance.

TAP No. 31 - If complaint is related to sexual misconduct or gender bias, see TAP No. 31, University Policy on Gender Discrimination and Sexual Misconduct.

TAP No. 55 - Ethical, Respectful and Professional Conduct. Complaints or disputes related to non-discriminatory issues between an employee and the supervisor or other university representative should be reported to the Office of Human Resources.

VI. Violations

As members of the Duquesne University community, all employees are responsible for sustaining the highest ethical standards of the University, and of the broader community in which we function. As such, employees are encouraged to report any violations of laws, regulations or University policies and procedure which come to their attention. Inappropriate activity can range from clearly illegal activity (such as the theft of University funds) to activity that is lawful but unethical (such as divulging confidential information or the unauthorized signing on behalf of the University).

Disciplinary actions for proven violations, or for improper retaliation against anyone who reports possible violations, will be determined on a case-by-case basis and may include actions up to and including termination of employment.

VII. History

This policy was established in March 2009 and last updated in June 2018.

VIII. Ownership of Policy

Office of the Associate VP for Finance and Business

Office of Anti-discrimination and Compliance