Reporting Suspected Wrongdoing and Protection from Retaliation
I. PURPOSE
The general purpose of this policy is to protect any University employee or other member of the University community who makes a good-faith disclosure of suspected wrongful conduct. This policy establishes the appropriate reporting mechanisms to be used for notification of known or suspected wrongdoing and protection from retaliation.
II. POLICY STATEMENT
Rockhurst University is committed to the highest ethical and professional standards of conduct. To achieve this goal, the University relies on each member of the university community to transact university business in compliance with all laws, regulations and University policies related to their positions and areas of responsibility, as well as to their behavior, honesty, integrity, and good judgment.
As stated in the University’s code of conduct (section 2-Employee Conduct, Employee Handbook), all Rockhurst employees are encouraged to report actual or suspected violations of laws, regulations or university policies or procedures, or other suspected wrongdoings that come to their attention, including violations of ethical and professional standards. Supervisors have a special duty to take reasonable steps to recognize violations in their areas of responsibility.
III. SCOPE
This policy applies to all members of the Rockhurst University community. Any individual who is a student, employee (whether full-time, part-time, or temporary employee), university official or any other individual employed by, or acting on behalf of, the University; other individuals on University property, including affiliates, employees of third-party vendors and contractors, volunteers, and visitors.
This policy does not replace or supersede existing mechanisms in other policies such as (for example):
- Procedures outlined for addressing employee misconduct in the Employee Handbook.
- Procedures outlined for addressing allegations of faculty misconduct in the Faculty Handbook.
- Procedures outlined for addressing academic grievances as outlined by the Student Consumer Complaint Resolution process.
- Procedures outlined in the Student Code of Conduct for addressing complaints against students.
- Procedures for addressing Sexual Harassment under the Sexual Harassment Policy or Discrimination/Harassment under the Non-Discrimination Policy.
IV. DEFINITIONS
- Retaliation: No person may intimidate, threaten, coerce, or discriminate against any individual because the individual has made a report, disclosure, or participated in or refused to participate in any manner in an investigation, proceeding, or hearing. Disciplinary action, harassment, unsupported evaluations, or other adverse changes in the conditions of employment or educational environment may also constitute retaliation.
- Employee: includes full-time, part-time, or temporary employees, including staff, faculty, adjuncts, and student employees.
- Wrongful Conduct includes, but is not limited to:
i. A violation of applicable state or federal laws or regulations.
ii. A violation of University policies, and/or the employee, faculty or student handbook;
iii. Use of University property, resources, or authority for personal gain or other non-University-related purposes, except as authorized by University policy.
V. PROCEDURES
A. Reporting Procedures
A caller can report any type of concern to the hotline. Examples of concerns include but are not limited to:
- Violations of the law
- Violations of University policy
- Any type of activity suggesting fraudulent reporting or misappropriation of funds
- Concerns regarding billing practices
- Sexual harassment
- Workplace misconduct
- Hostile work environment
- Breach of privacy
- Conflicts of Interest
The following channels are available to report suspected or actual Violations:
- Report it directly to your supervisor or department head or chair or Dean of your College. If the report involves a supervisor, report to the Human Resources office. Supervisors or other university offices receiving compliance reports should contact the Office of Compliance & Risk Management to determine next steps and should not investigate the matter themselves.
- University Offices: When circumstances for reporting to a supervisor or department chair or Dean are not a viable option, employees and other University community members can report concerns to the appropriate office listed below.
- Academic matters: Office of the Provost (provost@rockhurst.edu)
- Athletic matters: Department of Athletics-Director of Athletics: rockhursthawks.com/staff-directory
- Criminal matters: Department of Campus Safety (816) 501-4010; In Case of Emergency, call 911
- Employment matters: Director of Human Resources: 816-501-4555
- Sexual Discrimination/Harassment: Title IX Coordinator 816-501-4036; TitleIX@rockhurst.edu
- Financial matters: Chief Financial Officer 816-501-4862
- Office of Compliance & Risk Management: If a community member feels that concerns are not adequately addressed by the offices above or the individual does not feel comfortable speaking with them, the Office of Compliance & Risk Management may be utilized as a reporting source.
Rockhurst University
Kimberly Brant Schmelzle
Office of Compliance & Risk Management/Title IX Coordinator
Massman 3
Kimberly.brantschmelzle@rockhurst.edu
(816) 501-4036
- Rockhurst University Compliance & Ethics Hotline: Make a Report through the University Compliance & Ethics Hotline. Where individuals are uncomfortable discussing concerns with a University official, a confidential and anonymous report can be filed through the Compliance & Ethics Hotline. Mitratech (aka Syntrio) is a third-party ethics and compliance hotline provider that collects information anonymously. Reports can be made 24 hours a day, 7 days a week. The following are ways that you can contact the University hotline:
- Website:report.syntrio.com/CCH2255
- Anonymous Reporting App: Keyword: Rockhurst (PDF)
- Toll-Free Telephone:
- English-speaking USA and Canada:612-767-1341
- Spanish-speaking USA and Canada:800-216-1288
Contact us if you need a toll-free # for North American callers speaking languages other than English, Spanish or French.
- E-mail:standard-reports@mitratech.com (must include company name with report)
B. Initial Assessment of Reports and Investigation
Reports should provide sufficient, precise, and relevant information concerning dates, places, persons, numbers, etc., to allow for a reasonable investigation to take place. The University will review every report to the hotline.
Departments within the University that have responsibility for receiving reports or complaints through the hotline are the following: the President, Chief Financial Officer, Human Resource Office, Director of Compliance & Risk Management, and/or the External auditor for the University (Report Recipients hereinafter referred to as “Ethics Officers”). The report will be assessed by the Ethics Officers in consultation with appropriate university officials to determine whether it is actionable and whether it should be referred.
Examples of non-actionable reports include:
- Reports regarding conduct over which Rockhurst University does not have jurisdiction, such as off-campus conduct by an employee outside the scope of the employee’s university position.
- Reports that do not provide enough information.
- Reports of conduct that occurred more than a year prior. Note that the University may make exceptions to this general rule, depending primarily on the severity of the reported misconduct and the ability of the University to investigate it.
- Reports that do not, as alleged, present significant compliance concerns.
- Reports made in bad faith.
An investigation will be conducted if an initial assessment establishes that the report alleges Wrongful Conduct and if it is supported by sufficiently specific information or corroborating evidence. Other departments may become involved in investigations based on their areas of oversight responsibility or expertise. Reports that will be referred are those for which there is a dedicated policy or procedure. [See Scope of Policy, Sec. III].
The Ethics Officers will work with other senior management to ensure that prompt and appropriate corrective action is taken when and as needed, in compliance with any applicable policies. Employees will be given an opportunity to review and respond to relevant evidence prior to any disciplinary action being taken against them. Employees are encouraged to cooperate with any investigation under this procedure.
Depending on the nature of the complaint and the findings of any investigation, the University will take appropriate action, which may include disciplinary action, up to and including termination.
VI. Good Faith Complaint
This policy does not protect members of the University community who file a report or provide information that they know to be false or who provide information with reckless disregard for its truth or falsity. Anyone filing a complaint concerning suspected Wrongful Conduct must be acting in good faith and have reasonable grounds for suspecting the information disclosed indicates Wrongful Conduct. A member of the University community who is determined to have knowingly made a false accusation or provided false information in a report or during an investigation may be subject to disciplinary action up to and including termination or dismissal.
VII. Retaliation
No employee shall take retaliatory action against any individual who, acting in good faith, has reported a suspected Wrongful Conduct, assisted in making a report, cooperated in an investigation, or otherwise exercised their rights or responsibilities under this policy. An employee who feels that they have been retaliated against may file a written complaint following the Reporting Procedures in Section V. above.
Retaliation will not be tolerated and could result in suspension, reassignment, salary reduction, termination, expulsion, or other disciplinary action.
VIII. Confidentiality
The University will assess all reported alleged Wrongful Conduct under this policy and will make every effort to protect the identity of the person reporting alleged Wrongful Conduct. Rockhurst cannot guarantee confidentiality if identification of the reporting individual is necessary to the University for the purpose of investigating the incident.
IX. Policy Questions
Questions about this policy may be directed to the Office of Compliance & Risk Management.
X. Resources
- Investigation Report Template
- Rockhurst Internal Complaint Review Procedures for Compliance & Ethics Reports
Responsible Unit: Compliance & Risk Management Office
Approval and Updates:
President’s Cabinet August 2021
June 2025: changes to hotline reporting information
September 16, 2026: Updated policy (added broader application to University community, added sections for purpose, definitions, examples of reporting concerns, additions to reporting procedures, hotline information, and additional language in good faith complaint and retaliation), Investigation Report template created.
Review Cycle: Annual (or as needed)
Keywords: Whistleblower, Compliance Concern