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Preamble: Standards of Conduct and Integrity
All members of the University community, regardless of their location, are expected to conduct University-related business with honesty and integrity, and must comply with all governing rules, regulations and policies. Members include:
- employees (faculty and staff); and
- other individuals employed by the University, using University resources or facilities, or receiving funds administered by the University; and
- volunteers and other representatives when speaking or acting on behalf of the University.
Individuals who have a good faith belief that there has been a violation of local, state, or federal law or University policy governing any University activity, or that red flag indicators (possible warning signs) of potential misconduct exist, must report their concerns in one of the following ways:
- Report concerns to an appropriate University Administrator, e.g. supervisor, department head, etc. or other designated contact person within their unit.
- Contact the Central Office(s) responsible for handling the subject area directly.
- Contact the Office of Institutional Compliance directly
- Use the University’s reporting service, UReport, either via the online reporting serviceor by calling toll-free at 1-866-294-8680. The UReport service allows for anonymous reporting.
- In addition to any other report submitted under this section, concerns that University Funds or other public resources may have been used for an unlawful purpose shall be reported to the Office of Institutional Compliance, Office of Internal Audit, or via the UReport reporting system.
The individual reporting need not know the details of a law or policy or be certain about a violation.
All employees are expected to comply with any mandatory reporting obligations established in other policies, such as reporting related to sexual misconduct or the safety of a minor.
For more detailed information on reports related to sexual misconduct, see Administrative Policy: Sexual Harassment, Sexual Assault, Stalking and Relationship Violence.
Investigating Concerns of Misconduct
Appropriate University administrators are responsible for addressing reported concerns or forwarding the matter to an appropriate central office; conducting investigations (where needed); communicating with the reporter; contacting the Chief Compliance Officer when unsure of next steps; and escalating matters as appropriate to the Chief Compliance Officer, General Counsel, and Chief Auditor that:
- have the potential for serious or widespread legal or policy violations;
- has the potential to cause significant harm to any individual;
- significant accounting misconduct; or
- involve other matters that in their judgement represents a significant compliance concern.
Participation in an Investigation
University community members are required to participate in investigations related to suspected misconduct so that the most complete information is available when determining if the claim of misconduct is substantiated.
Protection from Retaliation
University community members are prohibited from retaliating (taking an adverse action) against an individual because of the individual’s good faith participation in:
- reporting or otherwise expressing opposition to, suspected or alleged misconduct;
- participating in any process designed to review or investigate suspected or alleged misconduct; or
- accessing the Office for Conflict Resolution (OCR) services.
A causal relationship between the good faith participation in one of these activities and an adverse action is needed to demonstrate that retaliation has occurred.
Individuals who believe that retaliation is occurring or has occurred, as a result of their good faith participation in one of the above referenced activities, should follow the reporting options available to them in this policy.
Reports of retaliation will be reviewed, investigated and resolved in the same manner in which other concerns of misconduct are handled. Individuals who engage in retaliation may be subject to disciplinary action up to and including termination of employment or expulsion.
Offices who receive concerns are responsible for keeping all related information, including information related to the investigation of the concerns, confidential to the extent provided by law.
Intentionally False Reports/Information
Individuals who, knowingly or intentionally, file a false report or provide false or misleading information in connection with an investigation may be subject to disciplinary action up to and including termination of employment, or expulsion.
Reason for Policy
This policy implements Board of Regents Policy: Code of Conduct and Board of Regents Policy: Safety of Minors and supports the reporting requirements in Minnesota Statute Section 625.556 (Reporting Maltreatment of Minors.) The University community's commitment to ethical conduct is detailed in Board of Regents Policies: Code of Conduct and Student Conduct Code. Board of Regents Policy: Code of Conduct addresses the University's responsibility to promote a culture of compliance which includes efforts to prevent, detect, and correct violations of law or policy, which may result from mistakes, lack of information, or, deliberate misconduct. A reporting system and protection against retaliation promotes compliance with law and policy and fair treatment of employees. This policy and the procedures attached to it support existing University policies and procedures for responding to reports of misconduct, and do not establish any additional rights beyond those already provided by law.