Reporting Suspected Wrongful Conduct

Responsible Unit: CEIS | Executive lead: President
Created: 08/26/2021 | Reviewed/Revised: N/A | Effective: 08/26/2021 
Compliance: NWCCU 2.D.2, 2.F.1
Approving Body: BOT | Classification: Institution wide 

Policy:  
PNWU is committed to operating ethically and lawfully and expects all members of the University community to perform their activities in compliance with the University’s Code of Conduct, policies, and procedures, and applicable law. Members of the University community have an affirmative duty to disclose and seek guidance if they believe that a member of the University community or person associated with or doing business with PNWU is engaging in wrongful conduct. The University encourages the communication of good-faith concerns and complaints of wrongful conduct. 

No member of the University community who in good faith reports any wrongful conduct or suspected wrongful conduct or who cooperates in good faith with a University inquiry or investigation of such a report will be subject to intimidation, harassment, discrimination, or other retaliation or, in the case of employees, adverse employment consequence. 

Any member of the University community who becomes aware of or suspects wrongful conduct shall report such wrongful conduct as soon as possible to their direct supervisor unless their direct supervisor is the subject of the complaint or otherwise involved. If so, the wrongful conduct may be reported to the Office of Compliance, Ethics, and Integrity Services (CEIS). 

Any person who receives a report of wrongful conduct shall contact CEIS. CEIS will assess each report on a preliminary basis to determine what action is required. Any person who receives a report of wrongful conduct involving CEIS or its members will contact the chair of the Compliance, Ethics, and Integrity Committee of the Board and the assessment of the report and subsequent action, if any, will be addressed by the CEI Committee of the Board. 

All CEIS directed inquiries will be conducted in a sensitive manner and information will be disclosed only as needed to facilitate the review of the inquiry materials and as otherwise required by law. The person who makes the report is expected to cooperate as necessary in connection with any report and inquiry or investigation. Any person who is the subject of a complaint may not be present at or participate in the deliberations or vote on the matter relating to such complaint, though they may present information as background or answer questions as requested beforehand. 

Where complaints are reported on an anonymous basis, the anonymity will be maintained, subject to applicable law. In the case of complaints not made on an anonymous basis but where confidentiality is desired or appropriate, confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review and subject to applicable law. Prompt and appropriate disciplinary and/or corrective action will be taken as warranted by the University. The Office of Compliance, Ethics, and Integrity Services will provide compliance oversight of any corrective action. 

Definitions:  
Complaint: Any act, behavior, or treatment perceived as unfair or unjust; can be written or oral; addressed/resolved informally or formally.​ 

Concern: Expression of worry or doubt for which reassurance is sought. 

Corrective action: Preventative, improvement, or modifying measures taken to promote compliance, ethics, and integrity. Corrective actions include but are not limited to education/training, policy revision/development, and procedure revision/development. 

Disciplinary action: Reprimand of an individual for misconduct, wrongful conduct, or poor performance carried out by immediate supervisor or most appropriate official, e.g., verbal warning, written warning, suspension, dismissal.  

Inquiry: Process of questioning and gathering of information to inform conclusions regarding a complaint. 

Investigation: Thorough and further questioning and gathering of evidence to uncover additional facts; may be conducted with/by external agency/experts. 

University community members: Trustees, employees, students, and volunteers. 

Wrongful conduct: Any action or omission taken by or within the University that is illegal, fraudulent, or in violation of University policies, procedures, or Code of Conduct. Wrongful conduct includes, but is not limited to, violations of law including fraud; unauthorized use of University property or resources; fraudulent or dishonest financial reporting, bribery, or kickbacks; and research or other academic fraud. 

Procedures: 
N/A 

Related Documents: 
PNWU Code of Conduct
PNWU Ethical Conduct Policy 
PNWU Whistleblower Policy 
Wrongful Conduct Complaint Process and Form 

Policy Resources

For assistance with policies and procedures contact:

Lori Fulton
lfulton@pnwu.edu