Office of Audit and Compliance

Hotline Policies and Procedure

Objective

The objective of the compliance hotline is to provide a confidential way for employees to obtain information about compliance issues and report instances of suspected non-compliance outside the normal chain of command in a manner that preserves confidentiality and assures non-retaliation. Employees should use the hotline when they are not satisfied with their supervisors' response to a compliance issue, or if they fear retaliation by their supervisors. Under normal circumstances, however, compliance issues should be addressed through normal administrative channels.

Examples of university activities and operations in which non-compliance may be an issue:

• Various UTD, state, or federal policies and procedures
• Grant or gift restrictions
• Safety policies and procedures
• NCAA guidelines
• Conflict of interest and ethics policies
• Computer security
• IRS regulations
• Equal Employment Opportunity laws
• Sexual harassment policies

Complaints

The compliance hotline is not a complaint hotline. Only matters involving compliance with a U. T. System or UTD policy or procedure, or a federal or state law or regulation, will be investigated. Employees with complaints will be advised to pursue normal administrative channels.

Supervision of Hotline

To insure anonymity, the university contracts with an outside service provider to manage its compliance hotline. The company is The Network. The toll free hotline telephone number is 1-888-228-7707. You can also report via the web at http://www.tnwinc.com/webreport.  Upon receipt of a call, the Network forwards the information to the University's Compliance Hotline Triage Team for resolution. This team consists of the Director of Audits and Compliance, the Associate Provost, the Assistant Vice President of Human Resources Management, the Associate VP for Business Affairs, and the Compliance Manager.

Confidentiality

Employees who call the compliance hotline may remain anonymous. If the person requests anonymity, no attempt will be made to identify the employee. Information provided by the employee will be treated as confidential and privileged to the extent permitted by applicable law.

Non-retaliation

Retalliation against an employee who has called the hotline is strictly prohibited. After placing a hotline call, if an employee perceives that he or she is being retaliated against, the employee will be referred to the appropriate administrative grievance procedure. Accusations of retalliation will be taken very seriously and agitators will face disciplinary action.

Employees who intentionally and maliciously use the hotline to make false allegations will be subject to disciplinary action.

Records Retention

A log will be maintained of all hotline telephone calls in the Office of Audit and Compliance. Hotline records will be maintained in a secure facility.

Investigation Procedures

After the Compliance Hotline Triage Team receives the information regarding the hotline call from the network, the team will determine the appropriate disposition of the issue. If the compliance issue involves an alleged fraud, the UT System fraud policy, Business Procedure Memorandum No. 50 , will be followed.

Resolution

All hotline compliance issues will be resolved as quickly as possible. Employees who call the hotline are given a code number and are asked to call back in two weeks to receive an update on actions taken to date. The Triage Team can also utilize this mechanism to communicate additional questions to callers who prefer to remain anonymous. Confidential information obtained during the investigation will not be disclosed to the employee. After the Compliance Hotline Team is satisfied with the resolution of the issue, documents pertaining to the call will not be retained.

Role of Legal Counsel

UTD's Audit and Compliance and/or Compliance Officer will consult U. T. System's Office of General Counsel when a major issue is reported via the compliance hotline.

HOTLINE
"It's Your Call"
1-888-228-7707
or
Via the website at
The Network's Web Reporting System