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Misconduct

On this page: Policy Statement · Reason for Policy · Policy Scope · Procedures · Frequently Asked Questions · Forms · Appendices · Additional Contacts · Definitions · Responsibilities · Related Information · History

Policy Statement

All members of the university community, regardless of their location, are expected to conduct university-related business with honesty and integrity, and must comply with all policies, procedures, rules, directives, legal and contractual obligations, and laws.

In accordance with the university’s community life standards, “all of its members must model Christ in their daily lives in a manner that will enhance spiritual growth and the common good.” As stewards of the university’s resources and property, we must make ethical decisions and avoid even the appearance of impropriety.

Reporting Misconduct

Individuals who have a good faith belief that there has been a violation of local, state, or federal law or university policy governing any university activity, including fraud, must report their concerns in one of the following ways:

• Report concerns to an appropriate university administrator or supervisor
• Report their concerns to the Office of Human Resources

It is the responsibility of every employee, supervisor, manager and officer to immediately report suspected misconduct or dishonesty to his or her supervisor. Supervisors, when made aware of such potential acts by subordinates, must immediately report such acts to the Office of Human Resources. If the employee’s concerns are related to the Office of Human Resources, the employee may go directly to the appropriate vice president.

All employees are expected to comply with any mandatory reporting obligations established in other policies, such as reporting related to sexual misconduct, bias, discrimination, harassment, racism, conflicts of interest, conflicts of commitment, or whistleblowing.

Any employee who has knowledge of misconduct by another employee and does not report such to university officials may be subject to disciplinary action, up to and including termination.

Reports may be submitted anonymously, although doing so may hinder the investigation and resolution of a complaint.

Lesser Claims

Misconduct is a serious claim concerning a breach of university policy. The university maintains an Employee Grievances policy that governs the handling of claims that do not rise to the level of misconduct.

Investigation and Sanctions

The Office of Human Resources or other designated administrator or group will investigate report of actual or suspected misconduct.

The Office of Human Resources, or other designated administrator or group will work with relevant university departments, personnel, and systems to determine the nature, validity, and extent of misconduct.

Confirmed violations will result in appropriate disciplinary action up to and including termination from employment, dismissal from the university, or termination of association or partnership. In some circumstances, civil and criminal charges and penalties may apply.

The university will not rely on a determination by a criminal justice authority to criminally prosecute as the basis for determining if an act is fraudulent or if misconduct has occurred.

Interim Measures

After the university has notified the involved parties that an investigation is warranted, or that any of the conditions listed above exist, the university may take interim action.

Interim action does not imply a finding but is a precautionary measure necessitated by serious circumstances. Such action can range from minor restrictions to paid or unpaid leave.

Cooperation Following Report and During an Investigation

University employees are required to cooperate with university investigative and disciplinary procedures and other involved law enforcement agencies in the detection, reporting, and investigation of fraud or misconduct, including the prosecution of offenders.

The reporting employee must refrain from further involvement in the matter unless directed otherwise by the Office of Human Resources or other formal university investigative body. Due to the important yet sensitive nature of the suspected violations, effective professional follow up is critical. Supervisors, must not perform any investigative or other follow up steps on their own.

The Office of Human Resources will follow-up on the matter which may include an investigation of the disclosure. The Office of Human Resources will acknowledge, and as appropriate and permissible by law and policy, provide confirmation of the status and outcome of the review.

Confidentiality

Reports of violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation, to comply with all applicable laws, and to cooperate with law enforcement authorities.

Officers, supervisors, and administrators that receive concerns are responsible for keeping all related information, including information related to the investigation of the concerns, confidential to the extent provided by law.

Retaliation

Retaliation as a response to such disclosure or the participation in a misconduct investigation will not be tolerated. Claims or instances of retaliation are subject the university’s Non-Retaliation policy. Notice of investigation or the occurrence of an investigation is not retaliation or an adverse action.

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Reason for Policy

Organizations are faced with the risks that come from wrongdoing, misconduct, dishonesty, and fraud. As with all business exposures, North Central University must be prepared to manage these risks and their potential impact professionally.

This policy defines employee and management responsibility for reporting fraud, potential or actual, or misconduct and to establish procedures for addressing wrongful conduct; and to protect any employee who engages in good faith disclosure of alleged wrongful conduct.

More specifically it:

• Encourages employees to disclose serious breaches of conduct covered by the university policies or state or federal law.
• Informs employees how allegations of wrongful conduct can be disclosed
• Prescribes how the university handles claims, reports, and investigations of misconduct.

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Policy Scope

This policy applies to all North Central University community members, including on campus and online students, employees, faculty, administrators, staff, applicants for admission, and to other individuals or entities, such as visitors, volunteers, vendors, consultants, third parties, or other individuals or entities that interact with any member of the university’s community, have any official capacity with the university, are present on university property, using university resources or facilities, or receiving funds administered by the university.

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Procedures

Addressing Claims of Misconduct

Assess Reports

The Office of Human Resources (or other designated administrator or deliberative group) receives reports of real or suspected misconduct. The Office of Human Resources or designee will determine if the claim best fits with investigative procedures related to this policy or if there is another appropriate procedure that should be utilized to address the report.

If there is an any imminent danger or threat, the Office of Human Resources or anyone else receiving a report should immediately notification law enforce and the university Campus Safety & Emergency Preparedness office.

Respond to Reports of Misconduct

1. The Office of Human Resources, designee, or anyone else receiving a report should gather the following:
   1. Name of complainant
   2. Misconduct details
      • Description of alleged violation or concern
      • Dates and locations (if applicable) of the alleged violation or conduct
      • Law or policy that was violated
   3. Name of person(s) alleged to have planned, participated in, known about, or potentially know about the alleged violation or conduct
2. The Office of Human Resources or designee will perform an initial investigation to evaluate the validity of the claim
   1. If further investigation is warranted, the Office of Human Resources will open a formal investigation
   2. If it is determined that an investigation is not warranted, the Office of Human Resources will communicate to the reporter how the conclusion was reached and close the inquiry.

Investigate Misconduct Claims

1. The Office of Human Resources or designee will determine who will investigate the claim. This may we the Office of Human Resources
2. The designated investigator creates an investigation plan, which includes:
   1. the scope and objective of the investigation;
   2. identification of the particular law(s) or University policy(s) that are alleged to have been violated;
   3. the names of the individuals who would be interviewed;
   4. the approach to be used for the interviews (e.g., interviewer, how they will be scheduled, where they will occur, sequencing of the interviews);
   5. list of support documentation to be requested; and
   6. the schedule or timeline for the investigation. A typical investigation should be concluded within 60 days of receiving the matter.
3. The investigator conducts the investigation (see Appendix: Best Practice for Conducting Interviews).
   1. Schedule interviews
   2. Conduct interviews
   3. Document interviews
   4. Gather additional documentation
   5. Summarize the information collected from interviews and other sources

Adjudicate Misconduct Claims

1. Investigator reviews all information to determine whether or not the allegations are substantiated.
2. Investigation determination
   1. If the allegations are substantiated, the investigator will:
      • Consult with the employee’s manager and other university community members
      • Determine corrective measures to be taken after consulting with university counsel, the President’s Cabinet, university community members, or university regents, as appropriate
      • Identify who will take the corrective measures and what the timeline will be.
      • Work with the Office of Human Resources and appropriate university leadership about what monitoring actions, if any, are needed
   2. If the allegations are not substantiated, the investigator will notify the complaint, and relevant university parties how the conclusion was reached and close the inquiry.
3. The investigator will work with the Office of Human Resources to provide a report summary for notification and for archival purposes.
4. The investigator will submit all supporting documents and evidence used in the investigation to the Office of Human Resources for archival purposes.

The Office of Human Resources or designee will notify all relevant parties about the determination, as appropriate.

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Frequently Asked Questions

Q: What counts as misconduct?

A: A violation of law, university policy, or handbook, such as theft, falsifying documents, mishandling money, bribes or kickbacks, misusing university resources, failing to report abuse of a minor, or using university property or authority for personal gain.

Q: How do I report misconduct?

A: Report it to an appropriate administrator, your supervisor, or the Office of Human Resources. If your concern involves the Office of Human Resources, go to the appropriate vice president.

Q: Do I have to report misconduct?

A: Yes. Every employee must report suspected misconduct right away. Employees who know about misconduct and do not report it may face discipline.

Q: Can I report anonymously?

A: Yes, though an anonymous report may make the investigation harder.

Q: What about smaller workplace concerns?

A: Concerns that do not rise to the level of misconduct go through the Employee Grievances policy.

Q: Should I investigate on my own?

A: No. Reporters and supervisors must not investigate or follow up on their own unless the Office of Human Resources directs them to.

Q: How long does an investigation take?

A: A typical investigation concludes within 60 days.

Q: Can someone retaliate against me for reporting?

A: No. The university prohibits retaliation against anyone who reports or takes part in an investigation.

Q: Who do I contact with questions?

A: Contact the Office of Human Resources at 612.343.4412 or hr@northcentral.edu.

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Forms

There are no forms associated with this policy.

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Appendices

There are no appendices associated with this policy.

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Additional Contacts

Subject	Contact	Phone	Email
Policy Clarification & Interpretation	Office of Human Resources	612.343.4412	hr@northcentral.edu

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Definitions

Adverse Action

Any action that might deter a reasonable person from engaging in reporting suspected or alleged misconduct, expressing opposition to alleged misconduct, participating in an investigation related to a misconduct allegation, or accessing the Office for Human Resources services. Examples of adverse action include, but are not limited to: impeding the individual’s academic advancement; departing from any customary academic or employment practice regarding the individual; firing, refusing to hire, or refusing to promote the individual; transferring or assigning the individual to a lesser position in terms of wages, hours, job classification, job security, employment or academic status; and threatening or marginalizing an individual. In some situations, retaliatory conduct may also include inappropriate disclosure of the identity of the individual who has made a complaint protected by this policy.

Good Faith Participation

Reporting, or otherwise expressing opposition to, misconduct based on a reasonable belief that misconduct has occurred. Or, honestly participating in an investigation of misconduct or accessing conflict resolution services.

Misconduct (Dishonesty)

The steps taken to analyze all relevant information regarding suspected or alleged misconduct and then determine whether sufficient evidence exists to find that misconduct occurred.

A violation of local, state, or federal law or university policy, or handbook. This includes, but is not limited to:

• Theft, misappropriation, misapplication, destruction, removal, or concealment of University resources including intellectual property;
• Forgery, falsification, or alteration of documents;
• Improprieties/misrepresentation in the handling or reporting of money or financial transactions;
• Authorizing or receiving payment for goods not received or services not performed;
• Misuse of University facilities, such as telephones, email systems and computers;
• Accepting or offering bribes, kickbacks, or rebates;
• Lack of reporting of actual or perceived abuse of a minor; and/or
• Actions related to concealing or perpetuating above mentioned activities.
• a serious violation of University policy;
• a serious violation of the University Code of Conduct;
• a violation of applicable state and federal laws;
• embezzlement or other financial irregularities; and/or
• the use of University property, resources, or authority for personal gain or other non-University related purpose except as provided under University policy.
• Other unlawful or similar acts.

Protected Action

Protected activities: include (i) reporting (whether internally or externally) or inquiring, in good faith, about suspected wrongful or unlawful activity; (ii) assisting others in making such a report; or (iii) participating in an investigation or proceeding related to suspected wrongful or unlawful activity.

Report in Good Faith

Ref – Good faith participation

Retaliation

Adverse action against an individual because she or he has made a protected disclosure or has participated in an investigation, proceeding or hearing involving a protected disclosure.

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Responsibilities

All Individuals

• Report good faith concerns about possible misconduct, including violations of local, state, or federal law or university policy governing any university activity.
• Be truthful and cooperative in investigations of alleged wrongdoing.

Individuals That Receive Reports

• Follow procedures for handling reported concerns.
• Escalate reports to appropriate university staff

University Administrators

• Enforce policy
• Administrate sanctions

Office of Human Resources

• Follow procedures for handling reported concerns.
• Investigate concerns of financial and operational misconduct.
• Work collaboratively with responsible offices to address concerns of misconduct and communicate results of these efforts according to established procedures.
• Consult with the university counsel, as appropriate.
• Communicate potential serious misconduct to the President’s Cabinet and the Board of Regents.
• Respond to concerns of retaliation.
• Annually notify employees of their responsibility to report concerns and where to report them.

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Related Information

Related Policies & Procedures

• Anti-Racism
• Bias, Discrimination, & Harassment
• Community Life Standards
• Conflicts of Interest and Commitment
• Employee Grievances
• Non-Retaliation
• Sexual Misconduct (Title IX)
• Student Code of Conduct
• Whistleblower Protection

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History

Amended

2026-10-01 – Non-substantive updates (e.g., titles, office names, and link corrections); moved the procedure onto the policy page; added frequently asked questions.

Issued

2021-09-30

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