1.0 Policy Purpose
The University maintains an Anonymous Reporting Hotline (Hotline) that provides a mechanism for individuals to report suspected violations of applicable laws, University rules, policies, or procedures, as well as ethical concerns or other allegations of misconduct (Reports). The purpose of this policy is to provide for how these Reports are addressed.
2.0 To Whom the Policy Applies
This policy applies to faculty, staff, students, and any other individual who makes a Report or is involved in addressing a Report.
3.0 Policy Statement
Brown University conducts its affairs ethically and in compliance with applicable laws and University rules, policies, and procedures. Individuals are expected to appropriately report ethical concerns and suspected violations of applicable laws and University rules, policies, and procedures.
The Hotline is available to make a Report; however, faculty, staff, and students are expected to initially discuss a concern with their immediate supervisor, or relevant dean, administrator, instructor, or advisor. In cases where these faculty or staff members are not available, or it would be inappropriate to report a concern to them, individuals should go to their supervisor’s supervisor. They should also use other established University reporting mechanisms, such as reporting concerns to:
- University Human Resources for allegations of inappropriate workplace behavior or work conduct;
- The Office of Institutional Equity and Diversity for allegations of unlawful discrimination or harassment;
- The Office of Research Integrity for allegations of research misconduct;
- The Office of Student Conduct and Community Standards for allegations of violations of the Student Code of Conduct; and to
- The Department of Public Safety for allegations of crime.
The University expects that individuals will make only Good Faith Reports of suspected violations using the Anonymous Reporting Hotline. The Hotline is not a 911 or emergency service and individuals should not use it for those purposes.
3.1 Addressing Reports
Reports received by the Hotline are managed in accordance with applicable University policies and procedures. University Risk Management, Audit, and Compliance reviews Reports and determines an appropriate manner to address them. If necessary, University Risk Management, Audit and Compliance will initiate an Internal Investigation to determine the relevant facts of the Report. The results of an Internal Investigation will be documented and, if appropriate, reviewed by Relevant University Leadership responsible for oversight and/or appropriate corrective action.
3.2 Confidentiality
The University will maintain the confidentiality of information provided by individuals who are interviewed or otherwise cooperate in an Internal Investigation and will only disclose such information to others within the University on a need to know basis and to outside parties where allowed or required by law.
To protect the confidentiality of individuals who participate in Internal Investigations, and to protect the integrity of the investigative process, individuals may not be informed of the outcome of an Internal Investigation.
3.4 Non-Retaliation
In accordance with the University's Non-Retaliation Policy, Code of Conduct, and the Code of Student Conduct, retaliation based on making a Good Faith Report or on an individual's cooperation with an Internal Investigation is prohibited.
4.0 Definitions
For the purpose of this policy, the terms below have the following definitions:
- Anonymous Reporting Hotline (Hotline):
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The University’s anonymous and confidential reporting system managed by a third-party provider.
- Cabinet Member:
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A member of the President’s Cabinet which is a standing committee of Brown senior leaders.
- Good Faith Report:
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A report made with an honest and reasonable belief that a violation of applicable law and/or University rules, policies, or procedures has occurred.
- Good Faith Reporter:
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An individual who makes a Good Faith Report.
- Internal Investigation:
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University-authorized internal examination, inspection, inquiry, analysis, or review to determine facts. An Internal Investigation is not a hearing or legal proceeding, and may be formal or informal. Internal Investigations may be transferred from University Risk Management, Audit and Compliance to a more appropriate University office with subject matter expertise, including, but not limited to the Office of the Provost, Vice President for Research, Office of Institutional Equity and Diversity, Office of General Counsel, University Human Resources, Athletics Compliance or Environmental Health and Safety. In certain situations (e.g., a conflict of interest, staffing limits), a decision may be made that an external entity will conduct the Internal Investigation.
- Relevant University Leadership:
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University leadership with the authority to direct and implement corrective action(s) based on the results of the Internal Investigation (i.e., stop and correct behavior, ensure no retaliation against a Good Faith Reporter, take appropriate disciplinary action where necessary).
- Report:
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An allegation of a violation of applicable laws and/or University rules, policies, or procedures or ethical concerns and/or other allegations of misconduct via the Hotline, or other established means.
5.0 Responsibilities
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.
- University Risk Management, Audit and Compliance:
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Manages Reports received from the third-party Hotline provider and may enter Reports received through other established means into the Hotline system to ensure they are handled according to University policies and procedures.
6.0 Consequences for Violating this Policy
Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.
Engaging in retaliatory behavior towards an actual or suspected reporter will be subject to disciplinary action up to and including termination of employment or association with the University.
7.0 Related Information
Brown University is a community in which individuals are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.
7.1 Related Policies:
7.2 Related Procedures:
7.3 Related Forms:
N/A
7.4 Frequently Asked Questions (FAQs):
7.5 Other Related Information:
Policy Owner and Contact(s)
Policy Owner: Provost and Executive Vice President for Finance and Administration
Policy Approved by: President
Contact Information:
Policy History
Policy Issue Date:
Policy Effective Date:
Policy Update/Review Summary:
This policy replaces the following policy:
- Fiscal Misconduct Policy and Procedures
Website Updated February 14, 2022