Home : Operational : Compliance

Commitment to Honest and Lawful Conduct. The University is committed to conducting its affairs honestly and in accordance with federal, state, and local laws and regulations and University policy. The University strives to prevent, detect, and swiftly correct violations of law or policy, which may result from inadvertence, mistake, lack of information, or, on a rare occasion, deliberate misconduct.

Reporting Concerns of Misconduct. University employees, contractors and agents are expected to report good faith concerns about possible violation of any policy, law, rule, or regulation governing any University activity. Employees are encouraged to attempt to resolve their concerns at the most local level, by reporting their concerns to their supervisor or other appropriate contact person within their unit. If employees feel uncomfortable addressing their concerns at the local level, or wish for any other reason to address their concerns elsewhere, employees may make their reports directly to University offices responsible for handling the subject area. Examples include:

• Athletics rules violations: Director of Athletic Compliance
• Discrimination and sexual harassment: Office of Equal Opportunity & Affirmative Action
• Environmental safety concerns: Department of Environmental Health and Safety

Individuals also are encouraged to report any good faith concerns to the University's confidential reporting service (toll-free 1-866-294-8680 or via a confidential Web link www.Ureport.ethicspoint.com). Reports will be directed to appropriate University administrators for resolution and investigation, as appropriate.

Investigation and Resolution. All employees, contractors and agents of the University are expected to be truthful and cooperative in the University's investigation of allegations. Appropriate University officials shall promptly address all good faith reported concerns. The University's General Counsel, Auditor, and Director of Institutional Compliance shall keep the President and the Board of Regents appropriately informed of any potential serious or widespread legal violations, significant accounting misconduct, or other matters that in their judgment represent a significant compliance concern.

Protection from Retaliation. Retaliation against employees for making good faith reports is prohibited. Employees making good faith reports of suspected misconduct should feel safe and protected from retaliation. The University shall provide appropriate support to reporting employees to protect against retaliation and respond to concerns of retaliation or unfair treatment linked to the employee's reporting.

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.

• Reporting and Addressing Concerns of Misconduct

There are no forms for this policy.

Subject	Contact	Phone	Fax/Email
Primary Contact	Gail Klatt	612-625-0150 612-625-1368	klatt003@umn.edu
Policy clarification	Office of Internal Audits	612-625-1368	612-625-1512
Legal Questions	General Counsel	612-624-4100	612-625-9624
Questions about reporting	Institutional Compliance	612-626-7852	612-626-7431
Anonymous/confidential reporting of legal/policy violations	Toll Free Outside Reporting Service	1-866-294-8680	www.Ureport.ethicspoint.com
Retaliation for reporting	Vice President for Human Resources	612-624-9817	612-624-6372

Appendix A: List and Description of Central Offices that Handle Concerns

Appendix B: Related Support Offices

Central Offices that Receive Reports

An office or position established by the University to receive and handle a report of misconduct, legal or policy violation. A list of these designated offices is set out in the Contacts, above.

Human Resource Liaison

A person assigned by the Vice President for Human Resources to assist in preventing retaliation or unfair treatment against individuals for having reported violations.

Confidential Reporting Service

A service the University has retained to receive reports of law or policy violations through a toll free number (1-866-294-8680) or Web site (www.Ureport.ethicspoint.com).

All Employees

Report good faith concerns about possible violation of any policy, law, rule, or regulation governing any University activity. Be truthful and cooperative in investigations of alleged wrongdoing.

Central Offices that Receive Reports

Follow procedures for handling reported concerns.

Collegiate/Unit Administrators

Follow procedures for handling reported concerns.

Contractors and Agents Providing Healthcare-Related Services

Abide by this policy. Communicate this policy and detailed information about the False Claims Act to employees working on behalf of the University.

Deans, Vice Presidents, Vice Chancellors

Annually notify employees of responsibility to report concerns and where to report those concerns. Ensure timely follow-up and resolution to reported allegations in respective college or unit.

Director of Audits

Investigate allegations of financial and operational misconduct. Communicate allegations received to proper administrators. Consult with General Counsel. Communicate with the President and the Board of Regents regarding potential serious financial or operational violations.

Director of Institutional Compliance

Administer confidential and anonymous reporting service. Ensure responsible offices handle reported concerns and communicate according to established procedures.

General Counsel

Handle investigations needing the protection of the attorney-client privilege. Consult with the Director of Audits. Communicate with the President and the Board of Regents regarding potential serious legal violations.

Human Resource Liaison

Collaborate with responsible administrators to respond to concerns about retaliation or unfair treatment against individuals for having reported violations.

Vice President for Human Resources

Appoint Human Resource Liaison to protect against retaliation when appropriate. Respond to concerns of retaliation.

• List and Description of Central Offices that Handle Concerns
• Related Support Offices
• Information for Healthcare Service Providers
• Owner View of Reporting and Addressing Concerns of Misconduct Process Flowchart
• Reported Concern Policy Flowchart (Owner View - Initial Version)

There is no FAQ for this policy.

• 31 U.S.C. § 3729 - False Claims Act
• Social Security Act § 1902(a)(68) - Information for Healthcare Service Providers
• Minn. Stat. § 181.932 - Disclosure of Information by Employees
• Minn. Stat. § 15.43 - Conflict of Interest
• List of Policies Related to Ethics
• Reporting Misconduct Website
• Resources for Student Concerns

Amended:

May 2007 - Amended Policy and added related information to meet new requirements in section 1902(a)(68) of the Social Security Act.

Amended:

July, 2005 - Changed policy title from "Dealing with Financial and Operational Misconduct" to current title, expanded scope, amended responsibilities, and revised procedures to reflect expanded scope and outside reporting service.

Amended:

March 2002 - Added procedure on Reporting NCAA Violations. Policy Statement, Contacts and Responsibilities sections revised to reflect the inclusion of NCAA violations in the policy scope.

Effective:

March 2000

To obtain a copy of a historical policy, e-mail the U Policy Librarian at policy@umn.edu or call 612-624-4372.