Whistleblower Policy

Policy Number: #300

Responsible Executive(s):

  • Senior Vice President and CFO

Responsible Office(s):

  • Financial Affairs

Date Revised: 12-07-2018

  1. Regis University has a responsibility for the stewardship of university resources and the public and private support that enables it to pursue its Mission. Regis University is committed to compliance with the laws and regulations to which it is subject and to promulgating university policies and procedures to interpret and apply these laws and regulations in Regis University setting. Laws, regulations, policies, and procedures strengthen and promote ethical practices and ethical treatment of all members of the Regis University community.

  2. Regis University’s internal controls and operating procedures are intended to detect and prevent or deter improper conduct such as the improper use of university assets, misappropriations, or improper commercial business transactions or activities. However, even the best systems of control cannot provide absolute safeguards against such irregularities. An employee who has a question about the propriety of any practice under university policies and procedures, should seek guidance from his/her supervisor or the university official who has responsibility for overseeing compliance with the particular policy or procedure. Intentional and unintentional violations of laws, regulations, policies, and procedures may occur and may constitute improper use of university assets, misappropriations, or improper commercial business transactions or activities. Examples of improper conduct are set forth in Exhibit A.

  3. An employee is encouraged to make such a report to his/her immediate supervisor. If the employee feels unable to do so or if there is any reason why this may not be appropriate, the employee should raise the issue with his/her manager, department chair, dean, director or the university office or official who has responsibility for overseeing compliance with the particular policy or procedure in accordance with the guidelines below. If the employee is not comfortable making a report with the overseeing office, they may make a report in accordance with this Whistleblower Policy.

  4. Anyone may report an allegation of improper conduct. A whistleblower report may be made by completing a form located at https://ajg.quickbase.com/db/bp3sqqkha or by calling (855) 961-0899. The report will be routed to the appropriate individuals at Regis University to determine the facts. In all instances, Regis University retains the prerogative to determine when circumstances warrant an investigation and, in conformity with this policy and applicable laws and regulations, the investigative process and/or disciplinary process to be employed with Regis University, and those who conduct Regis University’s business.

  5. A person or entity reporting improper conduct is commonly referred to as a whistleblower. Whistleblowers may be university employees (faculty or staff), applicants for employment, students, vendors, contractors, or a member of the general public. The whistleblower’s role is as a reporting party. Whistleblowers are not investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.

  6. Whistleblowers frequently make their reports in confidence. To the extent possible, within the limitations of law and policy and the need to conduct a competent investigation, confidentiality of whistleblowers will be maintained. Whistleblowers should be cautioned that their identity may become known for reasons outside of the control of the investigators or university administrators. Should the whistleblower self-disclose his or her identity, Regis University will no longer be obligated to maintain such confidence.

  7. Similarly, the identity of the subject(s) of the investigation will be maintained in confidence with the same limitations.

  8. It is a violation of Regis University policy to threaten, intimidate or retaliate in any way against an individual for acting as a whistleblower or raising good faith allegations of harassment or discrimination, participating in an investigation, complaint process or hearing, filing a complaint alleging harassment or discrimination, or encouraging others to report. Retaliation includes, but is not limited to, any form of intimidation, reprisal, or harassment. Regis University will take immediate and responsive action to any retaliation. Anyone found to have acted in a retaliatory manner may be subject to appropriate disciplinary action up to and including termination of employment or suspension from the University.

  9. This whistleblower policy does not address work-related conflicts and thus does not replace or supplant the Grievance Policy found in the Regis University Policies and Procedures Manual and in the appropriate Regis University Faculty Handbook, Section 6 et seq., under the circumstances described therein.

  10. Allegations that involve a Vice President, the President or a Trustee will be routed to the Chair of the Audit and Risk Management Committee of the Board of Trustees.


Exhibit A

 Examples of improper conduct include, but are not limited to the following:

  • Forgery or alteration of documents
  • Unauthorized alteration or manipulation of computer files
  • Fraudulent financial reporting
  • Pursuit of a benefit or advantage in violation of Regis University’s conflict of interest policy
  • Misappropriation or misuse of university resources, such as funds, supplies, or other assets
  • Authorizing or receiving compensation for goods not received or services not performed
  • Authorizing or receiving compensation for hours not worked
  • Knowingly allowing others to do a dishonest act