6.11 Ethics Hotline Policy
Purpose
Rochester University is committed to the highest possible standards of ethical, moral and legal business conduct. In conjunction with this commitment and the College’s commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. However, if an employee feels that their anonymity is not required, they should follow the existing grievance procedure outlined in the Whistleblower Policy (section 6.10).
Scope
This policy applies to all employees, including part-time and temporary individuals, as well as all officers and directors of Rochester University.
Policy
The ethics hotline policy is intended to cover serious concerns that could have a large impact on Rochester University, such as actions that:
- May lead to incorrect financial reporting;
- Are unlawful;
- Are not in line with College policy, including the Code of Ethics and Standards of Conduct; or
- Otherwise amount to serious improper conduct.
Regular business matters that do not require anonymity should be directed to the employee’s supervisor and are not addressed by this policy.
Safeguards
Harassment or Victimization
Harassment or victimization of individuals submitting hotline reports will not be tolerated.
Confidentiality
Every effort will be made to protect the reporter’s identity by Lighthouse, the hotline vendor. Please note that the information provided in a hotline report may be the basis of an internal and/or external investigation by Rochester University into the issue being reported. It is possible that as a result of the information provided in a report the reporter’s identity may become known during the course of the investigation.
Anonymous Allegations
The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be investigated, but consideration will be given to:
Malicious Allegations
Malicious allegations may result in disciplinary action.
Procedure
Reporting
The ethics hotline procedure is intended to be used for serious and sensitive issues. Serious concerns relating to financial reporting, unethical or illegal conduct should be reported in either of the following ways:
Reporters to the hotline will have the ability to remain anonymous if they choose. Please note that the information provided by you may be the basis of an internal and/or external investigation into the issue you are reporting and your anonymity will be protected to the extent possible by law. However, your identity may become known during the course of the investigation because of the information you have provided. Reports are submitted by Lighthouse to Rochester University or its designee, and may or may not be investigated at the sole discretion of the College.
Employment-related concerns should continue to be reported through your normal channels such as your supervisor, the Director of Human Resources, or a member of the administrative team.
Timing
The earlier a concern is expressed, the easier it is for us to take action.
Evidence
Although an employee is not expected to prove the truth of an allegation, the employee submitting a report needs to demonstrate in their hotline report that there are sufficient grounds for concern.
HOW THE REPORT WILL BE HANDLED
The action taken will depend on the nature of the concern. The Audit Committee of the Rochester University Board of Trustees receives a copy of each report and follow-up on their concern:
- Acknowledging that the concern was received;
- Indicating how the matter will be dealt with;
- Giving an estimate of the time it will take for a final response;
- Telling whether initial inquiries have been made;
- Telling whether further investigations will follow and, if not, why not.
Further Information
The amount of contact between the individual submitting a report and the body investigating the concern will depend on the nature of the issue, the clarity of information provided, and whether the employee remains accessible for follow-up. Further information may be sought from the reporter.
Outcome of an Investigation
At the discretion of the College and subject to legal and other constraints, the reporter may be entitled to receive information about the outcome of an investigation.
Rochester University reserves the right to modify or amend this policy at any time it may deem necessary.