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Home :: Policies :: Ethics and Compliance Hotline

Ethics and Compliance Hotline

Responsible Department
Human Resources
Effective Date
12/17/2015
  1. .

    Purpose

    1. In order to provide an ethical, efficient, and effective environment, it is important that all employees, students, and visitors at the University of North Georgia (UNG or the University) are able to provide important feedback regarding possible improper activities – and to be able to do so without fear of retribution.

    2. The University System of Georgia (USG) has made a consistent website available to each of its institutions as a hotline to be used for reporting of any activities perceived to be unethical, illegal, or in any way in violation of the standards of UNG or the USG. This policy outlines how that system is to be used.

    3. This policy sets forth a reporting mechanism for hotline complaints; however, depending on the nature of the complaint, additional University policies and/or procedures may detail the exact process to follow for investigation and resolution of a specific hotline complaint. For example, hotline complaints alleging sexual harassment, academic misconduct, poor work performance and conflicts with other employees will be investigated according to the applicable procedures set forth in the corresponding University policy.
  2. .

    Definitions

    Triage Team: For purposes of this policy, the Triage Team will be comprised of:

    1. Senior Vice President and Provost
    2. Senior Vice President for Business and Finance
    3. Director of Internal Audit
    4. Associate Vice President for Human Resources/Risk/Compliance
    5. Director of Risk Management and Compliance
    6. University General Counsel
  3. .

    Statement

    1. Reportable Conduct:

      1. Per USG policy, University employees have a clear responsibility to timely report wrongdoing. Wrongdoing is defined under this policy as violation of University policies, USG policies, state or federal law, violations of ethical and professional conduct, and fraud, waste or abuse. 

      2. Examples of wrongdoing include, but are not limited to, USG or UNG Code of Conduct violations, discrimination, harassment, research misconduct, academic misconduct and policy violations. Fraud, waste and abuse as well as harassment of any kind are of special concern to the University as these can impact our stewardship responsibilities and the well-being of individuals in the campus community.

    2. Complaint Review and Assignment:

      1. Within 48 hours of receipt of a complaint from operators of the hotline system provided to the University by the USG, the Executive Director - Human Resources/Risk/Compliance will respond to the reporter acknowledging receipt of the complaint. The Triage Team will evaluate each complaint. The triage team reviews the substance of the complaint and the parties involved to determine if a conflict of interest exists for any of the Triage Team members, to evaluate the complaint, to assign the complaint for investigation to a Triage Team member, and to discuss follow up. Any Triage Team member with a conflict of interest will be excluded from further access to the complaint and the complaint will be assigned to another Triage Team member.

      2. If a complaint alleges malfeasance, and additional information from the reporter is necessary for proper evaluation of the allegations, the Executive Director - Human Resources/Risk/Compliance will request the information from the reporter and provide a deadline for response. The complaint will not be evaluated for assignment until this information is received; if the information is not received within the prescribed deadline, the complaint will be closed and the reporter will be notified. The Executive Director - Human Resources/Risk/Compliance will notify the reporter of the complaint assignment. The Triage Team member assigned to investigate the complaint will abide by any deadlines in the hotline system, communicate with the reporter directly or through the hotline system, and document all investigation notes and summaries in the hotline system.

      3. Complaints involving potential fraud, waste, and abuse by an employee will be reported by the Executive Director - Human Resources/Risk/Compliance to the University Office of Internal Audit and USG Office of Internal Audit.

      4. Complaints of potential criminal malfeasance by an employee will be reported by the Executive Director - Human Resources/Risk/Compliance to the triage team and to the USG Chief Audit Officer.

      5. Issues involving members of the Triage Team or Executive Management of the University shall be referred to USG Chief Audit Officer.

    3. Reporting Concerns:

      1. Unless Unless otherwise indicated or circumstances make it inappropriate, employees should report significant concerns or wrongdoing through their supervisory chain. Other reporting avenues, however, are available, including Internal Audit, University Counsel, Public Safety, Human Resources, Business Affairs and University Ombudsman. Wrongdoing and significant concerns can also be reported confidentially on the Ethics & Compliance Hotline which is available at: https://ung.alertline.com/gcs/welcome 24 hours a day, 7 days a week.

        1. All employees involved with a hotline complaint are accountable and responsible for maintaining confidentiality. Due diligence and reasonable care must be exercised when handling confidential information. Employees involved in a hotline complaint should not discuss the matter with anyone outside their reporting chain, and when doing so, should not attempt to influence another employee’s responses during an investigation, should take measures to secure the investigative file so that its contents cannot be accessed by others and should not report on or release any information about the incident to internal or external parties without approval from the Office of Human Resources.

        2. The University and its employees may not interfere with the right of an employee to report concerns or wrongdoing and may not retaliate or take adverse employment action against an employee who, in good faith, has reported concerns or wrongdoing or has cooperated in an investigation. Retaliation violates federal and state laws, Board of Regents’ policies, and University of North Georgia policies. Alleged violations of this provision should be reported to the University’s Executive Director - Human Resources/Risk/ Compliance. Violations of this provision may result in disciplinary action up to and including termination.

        3. This policy does not protect an employee who files a false report or who provides information without a reasonable belief in the truth or accuracy of the information. Any employee who knowingly files a false report or intentionally provides false information during an investigation may be subject to disciplinary action which may include termination of employment.

    4. Investigation Actions:

      1. The triage team member assigned to the complaint is the case manager. If doing so will not compromise the investigation, the case manager will notify the individual named in the complaint that a complaint has been made through the hotline about him or her and that such complaint is under investigation. The accused will be notified of the University’s no retaliation policy and confidentiality policy. The case manager will also notify the unit head of the individual named in the complaint of the existence of the complaint and the pending investigation. 

      2. The scope of the investigation should include at a minimum, an interview with the individual reporter, if the reporter self-identified and the accused. Other individuals named in the complaint should be interviewed, only if a witness or if necessary, to substantiate or refute the allegations, with careful evaluation after each interview, using the procedures recommended by the USG Office of Internal Audit. All individuals interviewed will be reminded of the University No Retaliation Policy and the Confidentiality Policy. In addition, the case manager should review policy and procedures relevant to the complaint. 

      3. The investigator will document all relevant information to the case file and prepare a report summarizing the investigation to the Triage Committee. The Executive Director - Human Resources/Risk/Compliance will monitor the investigation and provide reminders to the case manager, if needed, to ensure swift resolution. The University’s goal is to have all matters resolved within 60 days, provide prompt and thorough communication to the reporter and the accused, and document the process in the hotline system.

      4. If an investigative report reveals that an employee has violated a policy or policies of the University or of the Board of Regents, that an employee or unit needs training on a particular topic, counseling, reprimand, suspension, termination, or any other corrective action, the matter will be referred to the employee’s supervisor and the Executive Director - Human Resources/Risk/ Compliance for resolution. In such instances, the employee and his or her supervisor will meet with Human Resources to review the matter and plan the corrective action(s) for the employee and/or unit. 

      5. The Executive Director - Human Resources/Risk/Compliance will communicate the planned corrective action and will inform the case manager when the corrective action has been completed. The final investigative report will reflect the completion date of the corrective action. If the investigation reveals a policy or procedure is needed or existing policy or procedure needs revising, the matter will be referred to the Executive Director - Human Resources/Risk/ Compliance for follow up.

      6. The Executive Director - Human Resources/Risk/ Compliance will document whether any corrective action is taken and enter the date of completion in the hotline system file.

      7. If an investigative report reveals that an employee violated city or county ordinance or state or federal law, the Executive Director - Human Resources/ Risk/Compliance will report this to the University and USG Office of Internal Audit and to law enforcement.

      8. If an investigation reveals that a student has violated the Student Code of Conduct, the case manager’s report will reflect this and the matter will be referred by the investigator to the Student Conduct Officer. 

      9. The reporter will be notified of the status of the investigation and the resolution and outcome of the complaint by the Executive Director - Human Resources/ Risk/Compliance or the Triage Team Investigator.

      10. The accused employee will be provided a copy of the final report by the Executive Director - Human Resources/Risk/Compliance.

    5. Tracking Complaints:

      1. The University will analyze all complaints to track and monitor trends or problem areas that may need focused management attention. Tracking of complaints will occur among offices and in particular subject areas. The University will provide additional controls, expanded policies or procedures, or additional management review if needed. All University personnel will be notified that retaliation by an employee that is the subject of a complaint is strictly prohibited and may subject the employee to termination and possible legal action.

      2. USG Compliance and Ethics Program staff will be consulted as needed, about appropriate responses to a hotline complaint. Any complaint and investigation about a USG President, or Vice President will have oversight of the University System of Georgia Office of Internal Audit.

    6. Complaint Management:

      1. The Executive Director - Human Resources/Risk/Compliance is responsible for managing the hotline. Complaints that escalate to an emergency level are immediately transmitted by the system’s hotline operators to the Chief of Police. Non-emergency complaints are emailed by hotline operators to the Triage Team. The Triage Team is comprised of the Provost, Internal Auditor, Vice President for Business and Finance, Executive Director - Human Resources/Risk/Compliance, and the Director of Risk Management and Compliance. All team members have participated in on-line training for the hotline system. Complaints received through the hotline are assigned for investigation in the same manner as face to face complaints according to University policy: Human Resource issues (performance, interpersonal relations, etc.) are assigned to unit heads while malfeasance complaints (fraud, waste and abuse) are handled by the hotline Triage Team. Complaints made to the Internal Auditor will be manually entered into the hotline by the Internal Auditor and managed as outlined in this policy.

      2. The Executive Director - Human Resources/Risk/Compliance is responsible for closing the case after the investigation is complete, all corrective actions are completed and documented in the hotline system, and all parties are notified of the resolution.
  4. .

    Support Info

    1. The University of North Georgia recognizes that an ethical, efficient, and effective work environment is essential to our continuing to successfully accomplish our mission. As a result, we have always placed a high priority on assuring that each member of our University community has the opportunity and means to convey any matter that could compromise that environment. Employees are encouraged to report such matters through his/her supervisory chain which frequently produces the most thorough and timely resolution of a matter. However, other reporting avenues, such as University Ombudsman, Public Safety, Internal Audit, Business Affairs, Human Resources, and University Counsel, have been and continue to be readily available.

    2. In keeping with the University’s efforts to expand alternatives for reporting matters of significance, reporting through the hotline service provided is available 24 hours a day, 7 days a week. The Hotline does not replace the existing reporting mechanisms noted above, but serves as an additional reporting mechanism. The hotline allows faculty, staff, students and visitors the option to confidentially report concerns and wrongdoing by telephone or on-line, and to remain anonymous if so desired. All new employees receive a hotline wallet card and brochure during new employee orientation and hotline posters are displayed in several prominent locations in each University building. A link to the University Ethics and Compliance Hotline exists on the UNG home page (www.ung.edu) as well on the University’s Human Resources home page (http://ung.edu/human-resources).
  5. .

    Procedures

    Any related operating procedures developed must comply with and reference this policy.

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