| Approved by: | The President |
| History: | Issued -- January 29, 2019 |
| Revised -- March 20, 2020 | |
| Last Reviewed -- March 20, 2020 | |
| Related Policies: | Code of Conduct for Staff and Faculty; Code of Student Conduct; Employee Indemnification Policy; Non-Retaliation Policy; Reporting Financial Irregularities Policy; Government and External Requests for Information Policy |
| Additional References: | |
| Responsible Official: | Chief of Staff and Counselor to the President tel. (202) 319-5104 |
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.
Per the Code of Conduct for Staff and Faculty and the Non-Retaliation and Reporting Ethical Misconduct Policy, suspected ethical misconduct must be brought to the attention of the appropriate University officials. A list of those officials appears at the end of this policy.
When a report of potential ethical misconduct or other wrongdoing is made, the University has a responsibility to investigate thoroughly, objectively, consistently, and as promptly as possible so that it can implement corrective action, if necessary. To meet this responsibility, employees of the University community must cooperate with University Investigations (defined below).
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 Officer, Title IX Coordinator, General Counsel, Human Resources, Internal Audit, and Public Safety.
III. Duty to Report
Individuals normally should report suspected 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 (see the list of officials at the end of this policy). Individuals also may make a report directly to the Director of Compliance (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU). In the event that the report pertains to the Director of Compliance, the report may be made to the General Counsel (tel. (202) 319-5142 or CUA-OGC@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 a safe and confidential reporting mechanism for reporting suspected ethical misconduct anonymously, and is administered by a third-party vendor (not the University). All reports forwarded by the third-party vendor to the Chief Ethics and Compliance Officer are investigated per University procedure.
IV. 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.
V. 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. Knowingly initiating or causing a false or bad faith report also is strictly prohibited. Violations of these provisions are subject to disciplinary action up to and including termination. All suspected reports of retaliation or bad faith reports should be reported immediately to the Director of Compliance (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU), to the Office of General Counsel (tel. (202) 319-4142 or CUA-OGC@CUA.EDU), or other senior level personnel.
Where to Report Suspected Ethical Misconduct
We must report non-compliance with a law, the Code of Conduct, a University policy, or other standard or requirement applicable to the University.