University of Rochester

Working at the University

Code of Conduct for Business Activities

I. B) Reporting of Suspected Violations

a. Duty to Report — To maintain the highest standards of business conduct, the University depends on each individual to report potential or perceived conflicts of interest involving themselves or others (discussed below) and suspected violations of applicable laws, regulations, government contract and grant requirements, or of this Code (together referred to as "violations"). Failure to report known or suspected violations is itself a breach of University ethical standards and can lead to discipline, up to and including separation from the University.

b. Reporting Procedures — Employees should understand that the University encourages reporting of violations and makes available a wide variety of ways that can be done. Personnel are encouraged to report violations to their immediate supervisor, but may also report to more senior management, to the Offices of Compliance, University Audit, or Counsel, or to the Integrity Hot Line, 756-8888. Supervisors or any other person who receives a report must in turn inform the Compliance Program Officer, who will decide whether to inform more senior management (e.g. the Dean, Director or Vice President of the school or division) and/or the Offices of University Audit and Counsel.

c. Confidentiality — Reports of suspected violations may be made confidentially, and even anonymously, although the more information given, the easier it is to investigate the reports. The University will take all appropriate steps to ensure the level of confidentiality desired, but sometimes the institution's legal obligations to investigate or address a violation will override the individual's wish for confidentiality. It is against University policy, and in many cases illegal, to retaliate against a person (e.g. by terminating a job) who reports a violation of law, regulation or grant or contract requirement.

d. Cooperation — All employees must cooperate fully in the investigation of any misconduct.

e. Annual Report — In addition to his or her responsibilities above, the Compliance Program Officer shall report annually to the Offices of Counsel and Audit, and to the Senior Vice President for Administration and Finance, regarding reports received under this Code.

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