Purpose

The Office of University Compliance (“University Compliance”) strives to prevent, detect, and assist management in addressing potential violations of policy, which may result from mistake, inadvertence, lack of information, or deliberate misconduct. This protocol establishes an administrative process for dealing with allegations of misconduct so that the integrity of the conduct of business at the University of Connecticut may be preserved.

Reported Concerns

University employees may report good faith concerns about possible violations of University policy to University Compliance. Although employees are encouraged to resolve issues by reporting concerns to  their manager, employees may not feel that adequate steps will be taken to resolve the expressed concerns or there may be a legitimate fear of retaliatory acts. Therefore, University Compliance maintains a private safe harbor to direct and receive compliance concerns for review, investigation, and resolution. Employees may report such concerns through the University’s Reportline by calling 1-888-685-2637 or through an online webform.

The identity of individuals who wish to report concerns to University Compliance anonymously will be protected to the extent possible under the law.^[1] However, the identities of individuals who report or are involved in matters concerning immediate threat to life or property, if known, will be disclosed to the proper authorities.

Retaliation against anyone who makes a good faith report is strictly prohibited. The University shall provide an appropriate response to  allegations of retaliation related to the reporting of compliance concerns, in accordance with the University’s Non-Retaliation Policy.

Review and Response

Upon receipt of a reported concern, University Compliance shall perform an initial assessment to determine whether sufficient information has been provided to conduct a thorough and fair review and/or whether the alleged conduct would constitute a violation of policy. University Compliance may request additional information or seek relevant documentation in an effort to perform the initial assessment.

If University Compliance determines there is sufficient information to conduct a review or investigation and that the report as alleged may constitute a violation of policy, University Compliance may consult with relevant University offices so that an appropriate plan to review may be developed, including identification of the most appropriate office or entity to review or investigate.

Notice of Investigation

When University Compliance retains a reported concern for investigation, the subject of the concern shall be notified in writing. In some circumstances, such notification will be delayed if University Compliance concludes it may risk the integrity of the investigation.

Information Collection

University Compliance will make reasonable efforts to obtain relevant information sufficient to reach a determination regarding the allegations. This may include conducting interviews and obtaining other documents and/or records.

University Compliance is authorized to have access to all University records, systems, facilities, and personnel necessary to conduct a thorough review of the concerns, except as may be restricted by law. All employees and units are expected to cooperate with any request University Compliance may make in an effort to access necessary evidence during the course of an investigation.

Cooperation

All individuals participating in the investigation are expected to fully cooperate and provide truthful information throughout the investigation. Failure to comply with these requirements is a violation of University policy and may result in further disciplinary action, up to and including dismissal.

Anonymity and Privacy

Anyone who wishes to report concerns to the Office of University Compliance anonymously will be protected to the extent possible under the law.^[1] To protect the integrity of the review and investigation process and to mitigate any potential instances of retaliation, any person engaged in the process will be asked to keep the matter private. However, the identities of individuals who report or are involved in matters where there is an immediate threat to life or property, if known, may be disclosed to the proper authorities.

Standard of Evidence

University Compliance uses a preponderance of the evidence standard, which is met when the information collected indicates it is more likely, than not, that a policy violation occurred.

Disposition and External Reporting

University Compliance will provide the final report to any appropriate University office for further action, as necessary. University Compliance may consult with the Office of the General Counsel and appropriate University officials to determine whether the matter should be referred to an appropriate external authority for review (e.g., State Auditors, Office of the Attorney General, Office of State Ethics). In circumstances where no recommendations are made within the final report, University Compliance shall close the file.

Timeline

All reasonable efforts will be made to complete investigations expeditiously yet thoroughly. University Compliance may provide the supervisor and subject of the investigation updates, when appropriate, regarding the estimated progress of the investigation.

Documentation

Appropriate records will be maintained that document the nature of the allegation(s), the investigation, the findings, and any recommendations for corrective action. Documents will be retained in accordance with relevant State statutes and University policies and procedures.

The University of Connecticut complies with all applicable federal and state laws regarding non-discrimination, equal opportunity, and affirmative action, including the provision of reasonable accommodations for persons with disabilities. Individuals with disabilities may request reasonable accommodation to participate in a University Compliance investigation process. Those who express a need for accommodation in the process should be referred to the appropriate office for assistance.

The Chief Compliance Officer (or designee) shall keep the President and Board of Trustees appropriately informed of any potential serious or widespread compliance concerns.

Effective: July 1, 2025

[1] Individuals may choose to disclose their identity or have no expectation of anonymity.