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Unethical Conduct Reporting

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  1. POLICY

    Employees must comply with all applicable laws, regulations, and policies when carrying out their duties. Employees should report suspected acts of non-compliance within the college. The College provides multiple methods for submitting reports. This policy provides for anonymous reporting processes.

  2. REFERENCES
    1. Utah Public Officers’ and Employees’ Ethics Act, U.C.A. § 67-16-1–15.
    2. Utah Protection of Public Employees Act, U.C.A. § 67-21-1–10.
  3. DEFINITIONS
    1. Abuse of Authority: an arbitrary or capricious exercise of power that adversely affects the employment rights of another, or results in a gain to the person exercising the authority or to another.
    2. Adverse Action: an action against an employee in a manner that negatively affects the employee’s employment status, including compensation, terms, conditions, location, rights, immunities, promotions, or privileges.
    3. Conflict of Interest: a discrepancy between the official duties and responsibilities of an employee and the employee’s private interests.
    4. Ethics and Compliance Hotline: a confidential platform managed by an external vendor for individuals to report unethical conduct.
    5. Good Faith: the reasonable belief and accurate restatement that observed conduct violates a law, regulation, or board of regents or college policy.
    6. Gross Mismanagement: the action or failure to act by an employee, with respect to the employee’s responsibility, that causes harm or risk of harm to the college or its mission.
    7. Retaliatory Action: conduct that causes an adverse action and includes threats and attempts to cause adverse action.
    8. Unethical Conduct: conduct that violates the Utah Public Officers’ and Employees’ Ethics Act, U.C.A. § 67-16, or SLCC policy Conflict of Interest, External Employment, and Consultations, or Employee Conduct. For example, abuses of authority, conflicts of interest, gross mismanagement, theft, fraud, or the waste, abuse, or misuse of college funds, etc.
  4. PROCEDURES
    1. Reporting Unethical Conduct
      1. The College provides several processes for employees to report suspected non-compliance with laws, regulations, and policies.
      2. Employees may report suspected non-compliance through various reporting mechanisms found on the #SLCCSafe reporting site.
      3. The College utilizes an Ethics and Compliance hotline for the reporting of unethical conduct.
    2. Presumption of Good Faith Reporting and Prohibition against Retaliatory Action
      1. A person making a report of unethical conduct is presumed to be acting in good faith.
      2. The presumption of good faith may be rebutted by showing that the employee knew or reasonably should have known the report was malicious, false, or frivolous.
      3. Malicious, false, or frivolous complaints will be referred to the director of Employee Relations or other appropriate college area for possible corrective action.
      4. A finding of no merit is not necessarily proof of a malicious, false, or frivolous complaint.
    3. Confidentiality

      Employees are encouraged to report unethical conduct on the record. If the employee does not want to be identified, the college will take reasonable precautions to prevent disclosure of the employee’s identity.

    4. Hotline Reporting
      1. The Ethics and Compliance Reporting Hotline (“Hotline”) is a reporting system that provides for anonymous and confidential communication.
      2. Anonymity and Confidentiality
        1. Anonymous reports to the Hotline are permitted. However, reports must provide sufficient information to warrant a review.
        2. While anonymity and confidentiality will be protected, persons making reports are encouraged to identify themselves and provide sufficient information.
        3. 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. 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. Anonymous reports may also be made to the:
          1. Chief Audit Executive,
          2. Office of the Commissioner of Higher Education, or
          3. Utah Office of the State Auditor.
    5. Hotline Administration
      1. The college has designated the Office of Internal Audit to review reports made to the hotline.
      2. Duties

        The Chief Audit Executive of the college serves the following functions:

        1. Receives Hotline reports.
        2. Conducts preliminary review to determine appropriate routing of Hotline reports.
        3. Routes Hotline reports to the appropriate department or external agency. Examples of routing include:
          1. criminal activity to Public Safety;
          2. discrimination to the Equal Opportunity office;
          3. employee misconduct or workplace bullying to Employee Relations;
          4. fraud or misuse of funds to the Office of Internal Audit;
          5. reports regarding cabinet members to the president and the Board of Trustees (BOT) Audit Committee; and
          6. reports regarding the college president to the Utah Board of Higher Education Audit director.
        4. Receives reports on process, findings, and action from the routed department or external agency.
        5. Determines when to close Hotline reports.
        6. Submits periodic reports on Hotline activity to the college president and the BOT Audit Committee.
      3. Processes for Hotline Administration
        1. Reports submitted to the Hotline are sent to the members of the Office of Internal Audit.
          1. If a member of the Office of Internal Audit is named in the Hotline report, it will not be sent to that staff member, and that staff member will not be involved in deliberations.
          2. Upon receipt of a Hotline report, the Chief Audit Executive will initiate a discussion with the Internal Audit Team within two business days.
        2. Within five business days, the Chief Audit Executive will route the Hotline report to an appropriate college official, department, or external agency(s).
        3. The Office of Internal Audit may conduct a preliminary review of the Hotline report to determine the routing decision and recommendation.
        4. The Chief Audit Executive may coordinate consulting with appropriate internal or external officials to make a routing decision.
        5. Within 10 business days of receiving the report, the Chief Audit Executive will update the person who made the report through the Hotline system, providing the routing determination and status of the report.
        6. The receiving college official or department must regularly update the Chief Audit Executive regarding the status of the Hotline report referral.
          1. The receiving college official or department must provide a report to the Chief Audit Executive with sufficient information to determine if the Hotline report should be closed in the system.
          2. The report should include the process(es), finding(s), and action(s) taken regarding the Hotline report.
      4. Upon receipt of the report, the Chief Audit Executive will determine whether to close the Hotline report or route it to another appropriate official.
      5. The Chief Audit Executive may consult with appropriate internal or external officials in its decision to close a Hotline report.
      6. The Chief Audit Executive may route the Hotline report to another official, department, or external agency if they determine that the recipient has not addressed the report satisfactorily.
      7. Upon determination to close the Hotline report, the Chief Audit Executive will update the person who made the report through the Hotline system.
      8. The Chief Audit Executive will provide reports of Hotline activity to the college president and the BOT Audit Committee.
    6. Retaliatory Action is Prohibited
      1. Retaliatory action against a person who has made a report or participated in an investigation is prohibited and may be subject to corrective action.
      2. If an employee files a retaliatory action complaint with the Ethics and Compliance Reporting Hotline, the Chief Audit Executive will refer the complaint to the associate vice president for People and Workplace Culture for review under the Employee Grievance Procedure. All employees will have access to the review process for retaliatory action complaints under that policy.

Last Revised: June 10, 2026

Last Approved: June 10, 2026

The originator of this policy & procedure is the director of Internal Audit. Questions regarding this policy may be directed to the originator by calling 801-957-4009.