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Policy No: 2064
Responsible Office: Compliance
Last Review Date: 11/14/2022
Next Required Review: 11/14/2027

Ethics and Compliance Hotline

1. Purpose

The Ethics and Compliance Hotline policy outlines a process for individuals doing work for or on behalf of the University of South Alabama (USA) to raise good faith concerns involving observed or suspected violations of state or federal law or regulation, or USA policies or procedures.

2. Applicability

This Policy applies to all Divisions of the University of South Alabama (USA), both the University General Division, and USA Health, and pertains to all individuals doing work for or on behalf of the University, including directors, officers, and other organization volunteers. Although primarily intended for employees, the Ethics and Compliance Hotline is also available for use by students if they wish to report violations of federal or state law, or university policy.

3. Definitions

Good Faith Disclosure: Means disclosure of University-related misconduct made with a belief in the truth of the disclosure that a reasonable person in the whistleblower’s situation could have believed based upon the facts. A disclosure is not in good faith if made with reckless disregard, or willful ignorance of facts that would disprove the disclosure. A report does not have to be proven true to be made in good faith.

University-related misconduct: Includes any activity by an individual doing work for or on behalf of the University that is undertaken in the performance of the individual’s work-related duties, whether or not such action is taken within the scope of the individual’s employment, that is a violation of any state or federal law or regulation, or University policies or procedures, including academic or research misconduct, conflict of interest or commitment, corruption, bribery, theft or misuse of University property, fraudulent claims, fraud, misappropriation of University or other agency funds, coercion, discrimination, sexual harassment, violations of civil rights, breach of patient privacy, breach of any person’s personal identifying information, and other illegal or improper practices.

Whistleblowing: Means good faith reporting of real or perceived University-related misconduct.

Whistleblower: Is any individual doing work for or on behalf of the University who, in good faith, reports real or perceived University-related misconduct. Whistleblowers do not include complainants who raise issues or concerns through the normal course and scope of the individual’s business-related duties.

4. Policy Guidelines

USA is committed to maintaining an environment where individuals doing work on behalf of the University are free to raise good faith concerns about alleged improper or wrongful activity. Individuals are encouraged to report suspected violations of state or federal law or regulation, or USA policies or procedures, and to provide truthful information in connection with any official inquiry or investigation.

USA encourages all subjects of this policy to first report concerns to one’s direct supervisor (direct chain of command). If for some reason a USA subject does not have confidence their immediate supervisor is addressing an issue appropriately, or fears retaliation for reporting an issue, USA maintains an Ethics and Compliance Hotline which features the ability to report anonymously.

5. Procedures

Reports of suspected violations of law or policy and reports of retaliation will be investigated promptly and in a manner intended to protect confidentiality as circumstances allow. Methods for reporting University-related misconduct or retaliation include:

  • To one’s immediate supervisor;
  • To the Office of Compliance;
  • To Human Resources Department, or;
  • To the Ethics & Compliance Hotline.

The Ethics & Compliance Hotline can be accessed as follows:

An investigation into reports of misconduct will be conducted by the individual designated in the applicable University policy, or as determined by the Ethics & Compliance Hotline Committee. Findings of University-related misconduct will be dealt with pursuant to the University’s policies and procedures.

The Ethics & Compliance Hotline offers anonymous reporting capability, but strongly encourages anonymous reporters to utilize their unique user name and chosen password provided by the Hotline in order to return to their report, either by Internet or telephone, and add more detail or answer questions posed by the assigned investigator. This process aids in necessary clarification / follow-up via an “anonymous dialogue.” The University will explore anonymous allegations to the extent possible, but will weigh the prudence of continuing such investigations against the likelihood of confirming the alleged facts or circumstances from attributable sources.

Individuals bringing forth allegations which are not made in good faith may be subject to disciplinary action independent of this Policy. Any questions regarding this policy should be directed to the Office of Compliance.

6. Enforcement

The Office of Compliance is responsible for this policy and seeks to assure all members of the USA community are aware of the policy, and abide by it.

7. Related Documents

Non-Retaliation Policy (Faculty Handbook, section 1.5.11, page 12)

Non Retaliation (Staff Employee Handbook, section 4.8)

Community Values and Code of Conduct