This Policy of Ethical Practice (the "Policy") covers a wide range of Robert Morris University practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide all employees of Robert Morris University and its subsidiaries (collectively referred to as "Robert Morris University" or the "University"). Robert Morris University employees must conduct themselves in accordance with this Policy and seek to avoid even the appearance of improper behavior. Robert Morris University's agents and representatives, including consultants, vendors and volunteers, are also expected to abide by this Policy.
Employees must comply with all applicable federal, state and local laws. If a provision of this Policy conflicts with a law, employees must comply with the law. This Policy supersedes all other codes of conduct, policies, procedures, instructions, practices, rules, or written or verbal representations to the extent that they are inconsistent with this Policy. However, this Policy does not supersede the provisions of any applicable collective bargaining agreement.
Robert Morris University continually reviews its policies and procedures and reserves the right to modify, supplement, amend or delete any provisions of this Policy.
- 2. Purpose
Robert Morris University seeks to promote:
- Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
- Full, fair, accurate, timely, and understandable disclosure in reports and documents that Robert Morris University files with, or submits to, governmental agencies and other external entities, as well as other public communications made by Robert Morris University;
- Protection of confidential information and proper use of the University's assets;
- Compliance with laws, rules, and regulations;
- Prompt internal reporting in good faith as described in sections 10-12 of this Policy; and
- Accountability for adherence to this Policy and other University policies.
- 3. Ethical Behavior
All Robert Morris University employees are expected to perform their job responsibilities in a manner that brings credit to themselves as individuals and reflects favorably on Robert Morris University. Robert Morris University proactively promotes ethical behavior, and encourages any employee to talk to supervisors, managers or other appropriate personnel when in doubt about the best course of action in a particular situation. The guidance set forth in this Policy, together with good common sense and one's own sense of right and wrong, are meant to guide decisions.
- 4. Conflicts of Interest
A "conflict of interest" exists when an employee's private interests interfere with, or even appear to interfere with, the interests of Robert Morris University. As an employee, one must be free of any actual or apparent conflicts of interest to assure the ability to exercise independent judgment with regard to Robert Morris University's best interests. No employee shall engage in conduct, or allow a situation to exist, in which the employee's personal interests conflict with his/her responsibility for honesty and fair dealings with Robert Morris University. Examples of a conflict of interest include but are not limited to:
- When an employee takes actions or has interests with a vendor or other entity that impairs his/her objectivity as it relates to Robert Morris University;
- When an employee, or a member of his/her family, receives improper personal benefits as a result of his/her position with Robert Morris University;
- When an employee conducts Robert Morris University business with a relative or significant other, or with a business with which a relative or significant other is associated in any significant role, without full disclosure to and approval by Robert Morris University; or
- When an employee serves as a director of any organization that competes with Robert Morris University, except as otherwise approved by Robert Morris University.
Conflicts of interest may not always be clear-cut. If an employee has a question, he/she should consult with his/her immediate supervisor, departmental vice president or senior vice president, or the Human Resources Department.
Employees should review and be familiar with Robert Morris University's policies related to accepting gifts. No one working on behalf of Robert Morris University shall offer or accept meals, entertainment or travel that can reasonably be interpreted as an attempt to improperly influence the recipient. Meals, entertainment or travel may never be solicited for individual benefit. Further, one may never give or accept them where it would be unlawful to do so or it would knowingly violate the policy of the other party's employer. If an employee becomes aware of an actual or potential conflict of interest, he/she should follow the reporting mechanisms in section 10 of this Policy.
- 5. Disclosures
Conflicts of interest are prohibited as a matter of Robert Morris University policy, unless the conflict is disclosed and approved on the Disclosure Form. The Disclosure Form outlines the completion and approval requirements and is located on the University website. Even if a transaction or other arrangement presenting an actual or potential conflict of interest has been disclosed and approved, the employee must also remove him/herself from any decisions being made related to the transaction or arrangement.
- 6. Officer and Key Employee Conflicts of Interest
Employees identified as Officers and Key Employees are required to comply with the alternate disclosure requirements of the Officer and Key Employee Conflict of Interest Disclosure Statement. Employees meeting the qualifications of these categories will be notified directly during each annual certification and disclosure period. Disclosures are reviewed and approved by the chair of the Board of Trustees (the "Board"), annually. If a conflict of interest arises after the annual disclosure period is complete, the individual is required to update his/her original Officer and Key Employee Conflict of Interest Disclosure Statement.
- 7. Financial Integrity, Disclosure and Other Reporting
Robert Morris University financial statements, and other data statements, must fairly and accurately present the financial condition and/or operational activity of the University. All transactions affecting Robert Morris University, directly or indirectly, shall be recorded properly, accurately and in a timely manner, and documented in Robert Morris University's books and records in accordance with University policies, U.S. Generally Accepted Accounting Principles and governmental rules and regulations.
Federal and state laws require Robert Morris University to disclose certain information in various reports that the University must file with or submit to government authorities. In addition, from time to time, the University reports other non-financial and operational data, and makes public communications, such as issuing press releases. Robert Morris University expects all employees who are involved in the preparation of these filings or other public documents to ensure that the information disclosed in the documents is fair, accurate, timely and understandable.
To the extent that an employee reasonably believes that questionable accounting, auditing, or other reporting conduct/practices have occurred or are occurring, he/she should utilize the reporting mechanisms in this Policy.
- 8. Confidentiality
Robert Morris University respects the privacy of its employees, students, vendors, and customers. The University's relationship with its campus community is built on trust and respect. Accordingly, Robert Morris University will provide confidential information to others only on a need-to-know basis for legitimate business purposes and in accordance with applicable laws. Employees must maintain the privacy of confidential information entrusted to them by Robert Morris University and its campus community, except when disclosure is authorized by the University's established written policies or required by laws or regulations.
Confidential information includes all non-public information that has been entrusted to us. The obligation to preserve confidential information continues even after employment ends. In connection with this obligation, every employee must comply with all University policies regarding confidentiality.
- 9. Protection and Proper Use of Robert Morris University's Assets
Employees should protect all Robert Morris University assets and ensure their efficient use. Any suspected incident of fraud or theft should be reported immediately using the reporting mechanisms in this Policy. Robert Morris University equipment should not be used for non-Robert Morris University business, although limited incidental or personal use is permitted with the approval of one's immediate supervisor. All employees should be familiar with and follow the Information Technology Acceptable Use Policy.
- 10. Reporting Responsibility and Mechanisms
Each employee of Robert Morris University has an obligation to promptly report any of the following (hereinafter collectively referred to as "Concerns"):
Violations of laws, rules or regulations; Fraud; Questionable or improper accounting matters; Theft, waste, or misuse of University resources or property; and other violations of this policy
If an employee has a Concern, he/she should not keep the information to him/herself, nor perform a personal investigation, but should promptly report via the mechanisms listed below:
Report to Management - Concerns should be reported initially through traditional reporting mechanisms, beginning with the immediate supervisor. If for any reason it is not appropriate to report suspected Concerns to the immediate supervisor, individuals should go to a higher level of management within their school or department. Other options for reporting internally include:
- Human Resources
- Internal Audit
- General Counsel
Reporting Hotline/Website - To the extent that reporting Concerns to management is not feasible or appropriate, and/or other resolution methods do not exist, employees may also report Concerns by calling the Policy of Ethical Practice Reporting Hotline at 1-800-963-5593 or submitting a report via the Web at www.ethicspoint.com.
- EthicsPoint is operated independently of the University to help ensure user confidentiality and, if desired, anonymity. If an employee chooses to report a Concern anonymously, he/she should provide very specific, detailed incident information to allow for appropriate investigation.
- For all hotline/website reported Concerns, the reporter will receive a report key to login and use to view the status of the Concern. Reporters are encouraged to check back regularly for questions or updates.
Employees are encouraged to report Concerns to management whenever possible. Anonymous hotline or website reports are often more difficult to investigate, and the credibility of such reports may be more difficult to determine.
- 11. Handling of Reported Concerns
Reports will be evaluated to determine if the subject matter of the report would constitute a potential violation of this Policy. If so, a thorough investigation will be conducted, and appropriate action will be taken. If it is determined that the subject matter of the report would not, even if verified, constitute a violation of this Policy, the reporter will be redirected to the most appropriate mechanism for resolution. All reports will be treated as confidential to the extent practicable. All employees are expected to cooperate in investigations and refrain from interfering with or obstructing an investigation, misrepresenting or withholding information, attempting to discover the identity of anyone cooperating in an investigation, or breaching the confidentiality of an investigation. Doing so will result in appropriate disciplinary action up to and including termination of employment.
Internal audit will regularly report investigation results of reported Concerns to the Audit and Risk Committee of the Board of Trustees for its review.
- 12. Acting in Good Faith
Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed is a violation of this Policy. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in appropriate discipline, up to and including termination of employment.
- 13. No Retaliation
No employee who in good faith reports a Concern shall be subject to retaliation or adverse employment consequences. Any employee who retaliates against someone who has reported a Concern in good faith is subject to appropriate discipline up to and including termination of employment.
- Frequently Asked Questions (FAQ)
Robert Morris University's EthicsPoint Reporting Hotline is not a 911 or Emergency Service. Reports submitted through the EthicsPoint Reporting Hotline may not receive an immediate response. If you require emergency assistance, please call 911.
Within this Frequently Asked Questions page, we will cover the following three categories: 1) General Questions, 2) Protection for Reporters, and 3) Student Concerns. Each category has specific questions and answers listed below. If your question is not answered within this page, please contact the Senior Director, Internal Audit at 412-397-5274, or firstname.lastname@example.org or the Director, Human Resources at 412-397-6277, or email@example.com.
What is EthicsPoint?
EthicsPoint is a comprehensive and anonymous Internet and telephone-based reporting tool that assists the University and its employees, students, and others in addressing concerns regarding violations of laws, rules, regulations or other non-compliance with the Policy of Ethical Practice. RMU contracted with EthicsPoint to provide the University hotline service 24 hours per day, 365 days per year. The hotline is staffed by EthicsPoint with specially trained personnel. When a reporter submits a reported concern ("Concern"), he/she may remain anonymous during the entire reporting process.
Why is the EthicsPoint Reporting Hotline necessary?
An anonymous reporting hotline is considered a best practice in the higher education industry. Many colleges and universities in the United States have implemented anonymous reporting hotlines.
Why are employees encouraged to report via traditional methods first?
Employees are encouraged to report Concerns to management whenever possible. Anonymous hotline or website reports are often more difficult to investigate, and the credibility of such reports may be more difficult to determine.
How does the EthicsPoint Reporting Hotline process work?
You may call the toll free number 800-963-5593 or submit an online Concern via the EthicsPoint Reporting Hotline Website. EthicsPoint takes the initial information and routes it to Robert Morris University's appropriate office to handle the investigation. Please see the Protection for Reporters section.
Does RMU think there is a problem with fraud or other wrongdoing at the University?
RMU believes in the integrity of our campus community and does not suspect any wrong doing. By establishing this confidential reporting tool, RMU strengthens its commitment to maintaining a safe, secure, and ethical environment.
Who is responsible for administering the program?
The Senior Director, Internal Audit and the Director, Human Resources are responsible for the administration of the EthicsPoint Reporting Hotline. Any questions can be addressed by contacting Dawn Maida at 412-397-5274 or firstname.lastname@example.org or Kristen Guy at 412-397-6277 or email@example.com.
Where does my Concern go once reported? Who at the University sees my Concern?
All Concerns are sent to the co-administrators and several senior leaders of the University. In addition, Concerns are communicated to specific University officials based on the nature of the Concern. Concerns are categorized by allegation category such as Academic & Other Student Matters, Financial Matters, Human Resources Matters, Information Technology Matters, Intercollegiate Athletics, Risk & Safety Matters, and Other. The co-administrators will share the Concern or parts of the Concern with others at the University who would need to see it for investigation purposes only. All Employees that see information from a Concern are required to keep this information confidential in accordance with the Policy of Ethical Practice.
How can I follow-up on a Concern?
When you file a report, either by calling the toll-free number or by submitting a report online, you will receive a unique username and be asked to choose a password. You will need to retain these to return to a report you previously filed. To follow-up on a report over the phone, call the toll free number and tell the interviewer that you are following up on a report. You will be asked for your username and unique password. To follow up on a report over the internet, go to the www.ethicspoint.com, choose "File a Report," enter "Robert Morris University" in the organization name field, click on the "Follow up on a Report" button, and enter your username and password. This will take you to the report you previously filed and a link to "Post a Follow-Up Note" or "Upload File." The university will provide a conclusion or status of the investigation after 10 business days. You may upload a file or post a follow-up note at any time.
Can I report employment concerns that are not policy violations?
The EthicsPoint Reporting Hotline is intended to investigate violations of laws, rules, regulations or of the Policy of Ethical Practice. If you have an employment concern that is not a violation, you should contact the Human Resources department.
Will I be told about the details about an investigation or its outcome/results?
In most cases, you will be told whether your reported issue was investigated, and whether it was resolved. There are, however, legal and other restrictions on what information the University is allowed to provide. For example, you may not be told about actions taken against a University employee or student as a result of your allegation because that information may be deemed "private" under applicable law. You also may not be told information that is deemed to be legally privileged or otherwise confidential.
What are my other reporting options?
Frequently, the best place to raise a concern or ask a question is within your own department and supervisor. You may also be able to raise your concern with specific University offices established to handle certain types of issues.
What if I have documentation (evidence) substantiating my Concern?
Using the web link - If the documentation is in an electronic format, you can upload it when you submit your Concern or at any time after that by using the identification key and password that was provided to you when the initial Concern was submitted. If the documentation cannot be uploaded, you should indicate that in your initial Concern or by posting a follow-up note to the anonymous reporting hotline. A co-administrator will post a follow-up comment providing guidance on how to submit the information.
Using the telephone option - If you make a Concern by telephone or are following up on a Concern by telephone, you should indicate to the operator that you have documentation that would help support the claim. The operator will provide guidance on how to submit the information.
Protection for Reporters
What if I want to file a Concern that involves my supervisor/manager or a University official that normally has access to view Concerns? Will they have access and see the Concern?
The EthicsPoint system and Concern distribution are designed so that no Concern is ever shared with implicated parties when their name and/or title are included in the report. Those involved in the investigation of a Concern will only share information with individuals that have a need to know based on the investigation plan. If you file a Concern anonymously, please refer to the question below addressing remaining anonymous.
If I file a Concern anonymously, will anyone at the University ever learn my identity?
The University will not learn your identity from EthicsPoint if you file an anonymous Concern. In some circumstances, however, your identity may nevertheless become apparent. For example, this may occur where the particular facts of the Concern suggest that it must have come from one person, or the reporter's identity becomes clear during the course of the investigation. In all cases, Concerns will be treated as confidential to the extent practicable and the University forbids retaliation based upon making a good faith report of a Concern.
How will individuals reporting Concerns be treated?
All matters related to your Concern will be handled with discretion. Reporting can be done anonymously. Individuals may choose to identify themselves and will not suffer any retaliatory action for reporting or inquiring in good faith. Please refer to the University's Policy of Ethical Practice.
What should I do if I feel I am being retaliated against for making the report?
The University prohibits retaliation for making good faith reports. If you believe you are the victim of retaliation for making a report, or have concerns about retaliation, you may utilize the EthicsPoint system or contact the Senior Director, Internal Audit at 412-397-5274, or firstname.lastname@example.org or the Director, Human Resources at 412-397-6277, or email@example.com.
What if I want to report an academic or other student issue?
If you are a student and have a concern related to your educational or student experience, you should file a report under the category "Academic & Other Student Matters". If you have concerns about misconduct involving University staff, faculty, volunteers, or other University representatives; or any other concerns about the safety of University facilities used by students, you should file a report to the appropriate category that corresponds to your situation. For example, if your Concern is about the safety of University facilities used by students, you should select the category "Risk & Safety Matters" to file a report. Similar to employees, all student reports must be made in good faith. Additionally, if your Concern can be reported to the applicable department, please do so.
What not to report here.
Certain categories of Concerns should not be reported through the EthicsPoint reporting hotline. Please direct the following types of Concerns to the appropriate office noted below or refer to the policies listed below:
- For Student-Faculty Disputes refer to the Student-Faculty Dispute Policy within the Academic Policies for Undergraduate and Graduate students.
- For Academic integrity issues, refer to the Academic Integrity Policy.