Unethical Conduct Reporting Policy

This policy was posted for public comment from February 2 – 18, 2026

Responses

General Comment

To prevent employees from being redirected between channels, the policy should provide clearer guidance on when concerns should be addressed through the grievance/Problem Solving (PWC) process versus the unethical conduct reporting process. Adding a brief distinction—along with cross references—and clarifying that issues may be rerouted internally when misfiled would help employees select the correct pathway and reduce confusion.

Section 4.E of the procedures section provides examples of routing of concerns. No change will be made to the policy statement.

Policy Statement (section 1)

The sentence, “Employees should report suspected acts of non-compliance within the college,” is overly broad and may be interpreted to include routine policy violations unrelated to ethical concerns. Consider narrowing the language to direct reporting toward “suspected unethical conduct,” with optional illustrative examples (e.g., fraud, conflicts of interest, misuse of funds) to clarify scope.

Thank you for the comment. We have reviewed the feedback and will leave the policy statement as written. The procedures section provides additional clarification on routing of concerns (Section 4.E.2.c).

3. Definitions

3.D. To strengthen employee understanding of the hotline’s structure and build confidence in its use, consider adding explicit language that the Hotline is administered by an external vendor. Clarifying practical implications—such as access limitations, how data is transmitted, and how confidentiality is preserved when reports go through a third party—would help employees make informed reporting decisions and reinforce trust in the process.

The definition of “Ethics and Compliance Hotline” has been expanded to note that the platform is managed by an external vendor.

3.G. “Retaliatory Action” is defined, but the procedures use the term “retaliation.” Suggestion to revise for clarity and consistency throughout the policy and procedures.

All instances of the term “retaliation” have been changed to “retaliatory action” so as not to conflict with the definition of retaliation as used in other SLCC policies.

4. Procedures

4.A.2 is unclear because employees may not know which office or department “has authority” to address a specific issue. If the policy’s intent is to prioritize the Ethics & Compliance Hotline as the primary mechanism for reporting unethical conduct, this section should list the hotline first and position other reporting options as secondary.

A link to the SLCCSafe website has been added to this section to provide an illustration of where different types of concerns can be reported.

4.A.3 – The hyperlinks for “Ethics and Compliance hotline” and “unethical conduct” currently point to the same destination. This may cause confusion for employees and undermine the purpose of providing separate references.

The hyperlink for “unethical conduct” has been removed.

4.B removes prior language clarifying that a “no merit” finding does not, in itself, indicate a complaint was malicious, false, or frivolous. Suggestion to reinstate this deleted language to avoid discouraging good faith reporting.

Language stating that “a finding of no merit is not necessarily proof of a malicious, false, or frivolous complaint” has been added back. See 4.B.4.

4.B is unclear about how bad-faith reporting is addressed in a way that avoids a back-and-forth complaint loop (e.g., an accused party filing a counter-complaint). If the intent is for the policy itself to distinguish between bad-faith reporting and retaliation and to provide a clear process for addressing them, this distinction should be made explicit.

This feedback has been considered. No changes will be adopted.

4.D.2(a) The phrase “sufficient evidence to warrant review” sets an important threshold, but the policy does not explain what kinds of information generally meet that standard. To help deter conclusory or vague accusations—and to set clear expectations for reporters—the policy could include a brief description of the types of details that typically make a report reviewable.

The term “evidence” has been replaced with “information”. A list of acceptable evidence may be impractical to provide in policy given the wide array of reports received by the hotline and will not be added to the policy.

4.D.2(c) leads with reasons why an investigation might not occur, which can read as defensive or dismissive. Reframing the section to emphasize what makes a report workable while still acknowledging that anonymous reports lacking detail can limit follow-up would strike a more positive tone and better support employee trust in the reporting process.

This section has been reworded as follows: “Matters will be reviewed to the extent possible, but some matters may require the person making the report to identify themselves for the matter to be fully investigated.”

4.D.2(c) – Related to the challenge of following up on anonymous reports, consider clarifying whether the Hotline vendor can act as an intermediary, allowing reporters to provide contact information to the vendor without disclosing their identity to the College.

The following narrative has been added: “Investigators may contact individuals through the hotline platform in a manner that maintains anonymity. Further, individuals making reports may provide clarifying information through the hotline platform while maintaining anonymity, if that is what the individual desires.”

4.E examples begin with “fraud or misuse of funds,” which may unintentionally signal that ethics reporting is primarily limited to financial misconduct. If the policy is intended to cover a broader range of unethical conduct, it may help to clarify that the listed items are illustrative.

The list under 4.E.2.c has been alphabetized.

Comments

Policy The current sentence (“Employees should report suspected acts of non compliance within the college”) is overly broad and may be interpreted to include routine policy violations unrelated to ethical concerns. Because this policy is intended specifically for reporting unethical conduct, consider narrowing the language to direct reporting toward “suspected unethical conduct,” with optional illustrative examples (e.g., fraud, conflicts of interest, misuse of funds) to clarify scope. To prevent employees from being redirected between channels, the policy should provide clearer guidance on when concerns should be addressed through the grievance/Problem Solving (PWC) process versus the unethical conduct reporting process. Adding a brief distinction—along with cross references—and clarifying that issues may be rerouted internally when misfiled would help employees select the correct pathway and reduce confusion.
References No Comments on References.
Definitions To strengthen employee understanding of the hotline’s structure and build confidence in its use, consider adding explicit language that the Hotline is administered by an external vendor. Clarifying practical implications—such as access limitations, how data is transmitted, and how confidentiality is preserved when reports go through a third party—would help employees make informed reporting decisions and reinforce trust in the process. The policy defines “Retaliatory Action,” but the operative sections use the term “retaliation.” If the intent is to rely on a defined term, the terminology should be consistent throughout. Consider either: renaming the definition to “Retaliation” to align with other College policies, or revising the operative text to use the defined term “Retaliatory Action.” Aligning terminology will improve clarity and ensure the definition applies as intended.
Procedures 4.A.2 is unclear because employees may not know which office or department “has authority” to address a specific issue. The wording also reads awkwardly and may lead to uncertainty about the correct reporting channel. If the policy’s intent is to prioritize the Ethics & Compliance Hotline as the primary mechanism for reporting unethical conduct, this section should present the hotline first and position other reporting options as secondary pathways. Clarifying the sequence and eliminating ambiguity about who has “authority” will make this section more user friendly and reduce reporting confusion. 4.A.3, the hyperlinks for “Ethics and Compliance hotline” and “unethical conduct” currently point to the same destination. This may cause confusion for employees and undermines the purpose of providing separate references. Each term should link to its respective resource or definition, or the policy should adjust the text so the duplication does not appear unintentional. 4.B removes prior language clarifying that a “no merit” finding does not, in itself, indicate a complaint was malicious, false, or frivolous. Unless the removal was intentional for structural reasons, the substance of that safeguard should be preserved to avoid discouraging good faith reporting. Without it, employees may worry that an unsubstantiated allegation could be treated as wrongdoing on their part. 4.B additionally, the policy is unclear about how bad faith reporting is addressed in a way that avoids a back and forth complaint loop (e.g., an accused party filing a counter complaint). If the intent is for the policy itself to distinguish bad faith reporting from retaliation and provide a clear process for addressing it, this distinction should be made explicit. 4.D.2(a) The phrase “sufficient evidence to warrant review” sets an important threshold, but the policy does not explain what kinds of information generally meet that standard. To help deter conclusory or vague accusations—and to set clear expectations for reporters—the policy could include a brief description of the types of details that typically make a report reviewable (e.g., who was involved, what occurred, when/where it happened, and any supporting documentation). This would improve clarity and reporting quality. 4.D.2(c) (“Some matters may only be fully investigated…”) leads with reasons why an investigation might not occur, which can read as defensive or dismissive. Reframing the section to emphasize what makes a report workable while still acknowledging that anonymous reports lacking detail can limit follow up would strike a more positive tone and better support employee trust in the reporting process. 4.D.2(c) Related to the challenge of following up on anonymous reports, consider clarifying whether the Hotline vendor can act as an intermediary, allowing reporters to provide contact information to the vendor without disclosing their identity to the College. This option would enable investigators to request additional detail when needed while preserving anonymity, improving both investigatory quality and reporter protection. 4.E examples begin with “fraud or misuse of funds,” which may unintentionally signal that ethics reporting is primarily limited to financial misconduct. If the policy is intended to cover a broader range of unethical conduct—including issues such as abuse of authority, conflicts of interest, or other compliance related ethical concerns—it may help to clarify that the listed items are illustrative. This would prevent employees from assuming non financial issues fall outside the ethics reporting process.

SLCC Policies and Procedures