Business Procedures Manual

Essential business procedural components for University System of Georgia institutions.

16.5 Ethics and Compliance Reporting Hotlines

16.5.1 Purpose

(Last Modified on November 13, 2014)

The Ethics and Compliance Reporting Hotline was implemented in January 2008 as part of a comprehensive ethics and compliance program that was designed to promote the highest standards of ethical and professional conduct within the USG. The hotline allows concerns to be reported confidentially by phone or on-line. The hotline is administered by a third party vendor that provides for confidential communication. The hotline does not replace existing reporting mechanisms, including reporting concerns to an employee’s supervisor, but rather serves as an additional reporting option. Each institution has a hotline web address and a telephone number assigned to it. A list of the web address and telephone number for each institution can be accessed from the following web address:

http://www.usg.edu/audit/compliance/reporting_contacts


16.5.2 Procedures

(Last Modified on November 13, 2014)

This policy sets forth the minimum requirements for the administration of each institution’s Ethics and Compliance Reporting Hotline. Other institutional or USG policies may provide further guidance relating to allegations of specific conduct, such as sexual harassment, academic misconduct, poor work performance, and conflicts with other employees.


16.5.3 Implementation

(Last Modified on November 13, 2014)

To implement this policy, each institution shall document its procedures for receiving, investigating and resolving hotline reports. The Ethics and Compliance Reporting Hotline is an additional method of reporting concerns and wrongdoing, but does not replace existing processes for investigating and resolving reports of wrongdoing. As such, a policy for receiving and reviewing specific allegations of misconduct already may be in place at each institution. Reports received on the hotline do not require institutions to establish a duplicate process for investigating such concerns or wrongdoing. The procedures established at each institution, however, must comply with the provisions of this policy.


16.5 4 Administration and Responsibility for the Ethics and Compliance Hotline

(Last Modified on November 13, 2014)

The president of each institution shall appoint an administrator who will serve as the Ethics and Compliance Reporting Hotline Coordinator. Each USG institution is encouraged to establish a triage committee to review and manage reports received on the hotline. Triage committee members may include representatives from internal audit, the office of legal affairs, compliance, human resources, public safety/campus police, information security or other functions at the discretion of the institutional president. However, all reports received regarding potential fraud, waste and abuse must be provided to the internal audit department.

If a triage committee is established, it is this committee’s responsibility to monitor the institutional Ethics and Compliance Reporting Hotline and to ensure appropriate remediation of hotline issues. Absent a formal triage committee, the Hotline Coordinator is responsible for ensuring compliance with this section. Issues involving members of the triage committee or institutional executive management shall be referred to the USG Office of Internal Audit and Compliance for remediation and/or investigation.


16.5.5 Confidentiality

(Last Modified on November 13, 2014)

All employees involved in the process of receiving and investigating reports of wrongdoing must exercise due diligence and reasonable care to maintain the integrity and confidentiality of the information received. All USG employees must ensure they comply with state and federal laws regarding whistleblower protection.


16.5.6 Investigative Processes

(Last Modified on November 13, 2014)

A. Evaluation: Each institution will include in its written procedures, a process for evaluating and resolving complaints received on the hotline, assigning a case manager, establishing and maintaining communications with all appropriate parties, establishing an estimated timeframe for the resolution of reports received, and ensuring that cases are properly documented and closed. The evaluation process shall also include determining if the concerns raised in the report should be directed to a particular supervisor for remediation or to a department or office for investigation in accordance with previously established policies and procedures of the institution.

B. Case Manager: A case manager will be assigned to all hotline reports received. The case manager will be responsible for the proper handling of the case, including determining if the case should be directed to a department or office in accordance with previously established policies and procedures, the assignment of additional investigators (if needed), conducting interviews, documenting all relevant information in the case file, ensuring that timely communication is maintained with all appropriate parties, including the reporter and the accused, ensuring that any required corrective action is taken, and closing the case in the hotline software in a proper and timely manner. If a case is directed to another department or office for remediation, the case manager maintains the responsibility to ensure the case is properly resolved, that appropriate communication is maintained with all parties and for closing the case on the hotline software.

C. Communication with the Reporter / Complainant: A response to the reporter / complainant shall be made within two (2) business days of the receipt of the hotline report that, at a minimum, acknowledges receipt of the report. The reporter also may be asked to provide additional details to assist in evaluating and resolving the matter reported. The reporter shall be kept informed of the status of the investigation and shall be notified concerning the resolution of the case and the action taken.

D. Communication with Named Persons: Named persons alleged to have committed a violation shall be notified of the allegations made and shall be kept informed of the status of the investigation. Notification shall be made at the time and to the extent that the case manager determines that it will not affect the integrity of the investigation.

E. Corrective Action: Any recommended corrective action pertaining to USG employees will be taken by or coordinated with the institution’s Human Resources Department. Corrective action includes, but is not limited to, recommended training, retraining, counseling, reprimands, suspensions and the termination of employment, consistent with the institution’s progressive discipline policy and other applicable Board and human resources policies.

F. Closing the case: Once all necessary investigative acts have been completed and properly documented, the administrative process to properly and promptly close the case must be completed, which shall include, at a minimum, notifying the reporter/ complainant, documenting the resolution and action taken, and making the required entries on the hotline software in a manner that the date on which the case is closed is properly documented.


16.5.7 Tracking and Analyzing Reports

(Last Modified on November 13, 2014)

Each institution shall analyze, track and monitor reports to identify trends or problem areas. Updates regarding the number and types of cases shall be provided by the University System Office to the Board of Regents.


16.5.8 Access to the Ethics and Reporting Hotline and Other Reporting Processes

(Last Modified on November 13, 2014)

A. On-Line Link to Ethics and Compliance Reporting Hotline: Each institution shall provide an on–line link to its Ethics and Compliance Reporting Hotline on the home page of the institution’s website or other prominent location accessible by employees, students, and the public.
B. Additional Reporting Contact Information: Each institution is encouraged to publish all of the reporting options pertaining to that institution’s processes and procedures on one web page. Further, each institution is encouraged to provide a listing of alternative reporting contacts for suspected wrongdoing that is widespread, or concerns the USG System as a whole. The additional reporting contacts should include but are not limited to the following:

  1. The Ethics and Reporting Hotline for the University System Office
  2. The USG Chief Audit Officer
  3. The USG Legal Affairs Office
  4. The USG Director of Ethics & Compliance

(Last Modified on November 13, 2014)

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