| Approved by: | Board of Trustees |
| History: | Issued -- July 21, 2011 |
| Revised -- March 20, 2020 | |
| Last Reviewed -- March 20, 2020 | |
| Related Policies: | Code of Conduct for Staff and Faculty; Internal Investigations Policy; Student 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 the University's mission and policies. To promote a culture of ethics and compliance, suspected ethical misconduct 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 for Staff and Faculty, the Student Code of Conduct, or other standard or requirement applicable to the University.
The University investigates reports of suspected ethical misconduct thoroughly, objectively, consistently, and as promptly as possible.
Retaliation against members of the University community for making good faith reports or for cooperating with investigations is strictly prohibited, even when such reports turn out to be erroneous. Knowingly initiating or causing a false or bad faith report also is strictly prohibited. Violations of these prohibitions are subject to disciplinary action up to and including termination.
II. Reporting Ethical Misconduct
A. Normal Administrative channels
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 Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU). In the event that the report pertains to the Chief Ethics and Compliance Officer, the report may be made to the General Counsel (tel. (202) 319-5142 or CUA-OGC@CUA.EDU.)
Individuals’ confidentiality 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).
B. Reporting Anonymously
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.
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.
Likewise, knowingly initiating or causing a false or bad faith report is strictly prohibited.
Violations of the foregoing non-retaliation and bad-faith reporting provisions are subject to disciplinary action up to and including termination.
VI. Interim Measures
While a complaint is pending, the University may take interim measures, including but not limited to no contact orders, reassignment, changes in work duties, suspension with pay, or suspension without pay.
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.