A key element of an effective compliance program is to have a robust reporting system - one that allows employees to anonymously or confidentially report suspected or actual violations and to seek guidance - without fear of retaliation. Through UVM's Whistleblower Policy, Code of Conduct and its compliance reporting mechanisms, the University encourages and facilitates good-faith reporting. Non-retaliation is also a theme across many University Policies and University Operating Procedures (UOPs). Go to the Policy site and search for "retaliation" to see just how many UVM Policies and UOPs expressly prohibit retaliation.

Good-faith reports help maintain a positive work environment and support our shared values in "Our Common Ground." As much as we encourage good-faith reporting, we also know that reporting issues of non-compliance can be difficult. As Jimmy Dugan said in A League of Their Own, "If it were easy, everyone would do it." The fear of retaliation, however, should not be something that prevents reporting.

You have options if you ever find yourself in a situation where you're asking yourself questions like:

"Is this right?"

"Am I OK with this?"

"I'm not sure what to do"

To encourage good-faith reporting, UVM has set up multiple reporting mechanisms, one of which is the Compliance & Ethics HelpLine ("the HelpLine") that allows you to anonymously report suspected violations to laws, regulations, UVM Policies and Procedures and to the compliance program. You can make reports using the HelpLine either online or by calling 877.310.0413.

Anyone who makes a report in good-faith will be protected from retaliation. Even if, after investigation, the allegation was not substantiated, if the report was made because you knew or reasonably suspected that wrongdoing occurred/is occurring, you will be protected. The same cannot be said for bad-faith reports, however.

Retaliation can be subtle or blatant, it can come from supervisors or peers. Among other things, it can take the form of unwarranted or improper disciplinary action, transfer or demotion. It can look like the whistleblower is being excluded from meetings or office gatherings. It can feel like the whistleblower is being ignored or shunned by co-workers. Retaliation is not, however, disciplinary action for job performance issues or management decisions unrelated to compliance reports.

Those who make reports that are knowingly false or otherwise made for improper motives are not protected by the Whistleblower Policy. These types of reports are made in bad-faith and are, themselves, violations under the Code of Conduct. The Whistleblower Policy cannot be used as a shield against job performance issues. An employee who has past job performance issues who subsequently files a bad-faith report to try and prevent disciplinary action will not be protected under this policy.

If you feel you've been retaliated against for reporting a compliance concern, tell someone... your Labor and Employee Relations Professional, or to our office. You are not alone. If it turns out that the retaliation occurred, those who violated one of UVM's non-retaliation policies will face disciplinary action. In addition, if the retaliation violates one of the federal or state whistleblower protection programs, violators may also face legal action above and beyond any internal disciplinary action.

Please visit the Whistleblower Policy: Reporting, Protections & Non-Retaliation, the Code of Conduct and Ethical Standards and the Help Line FAQ website for more details. If you have any questions about this ComplianceALERT, contact the Office of Compliance and Privacy Services at compliance@uvm.edu.