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About This Policy

Responsible Office
Vice President of Human Resources & Operations

Policy Owner
Vice President of Human Resources & Operations

Policy Contact
Vice President of Human Resources & Operations


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 Grievance 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.


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 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 Retaliation policy. Notice of investigation or the occurrence of an investigation is not retaliation or an adverse action.

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.

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.


  • Addressing claims of misconduct


  • There are no forms associated with this policy.


  • There are no appendices associated with this policy.

Additional Contacts

Policy Clarification & InterpretationOffice of Human


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


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.


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 senior leadership and the Board of Regents.
  • Respond to concerns of retaliation.
  • Annually notify employees of their responsibility to report concerns and where to report them.