DeVry Education Group Ethics and Compliance Services Policy C-1. Speak Up: Asking Questions & Raising Concerns

Transcription

1 DeVry Education Group Ethics and Compliance Services Policy C-1 Speak Up: Asking Questions & Raising Concerns Effective Date: April 30, 2010 Revision Date: December 01, 2013 Policy Owned by: Ethics and Compliance Services Policy Maintained by: Ethics and Compliance Services 1

2 Table of Contents I. Purpose II. Policy Statement III. Scope IV. Key Policy Definitions V. Related Policies and Additional Resources VI. Policy Requirements A. Duty to Speak Up. 3 B. Where to go with questions and concerns C. Zero-tolerance with regard to retaliation D. Zero-tolerance with regard to bad faith allegations....5 E. The Ethics and Compliance Services HelpLine and HelpSite...5 F. Protecting your anonymity and confidentiality...6 G. What happens after I Speak Up?...6 2

3 I. Purpose. This policy is the centerpiece of the DeVry Education Group s Speak Up compliance program, an integral part of our Ethics and Compliance Services program. This policy is designed to encourage colleagues of DeVry Education Group and its educational institutions ( DeVry ) to ask legal, compliance, or ethics questions, to raise concerns, and to report suspected wrongdoing without fear of retaliation. II. Policy Statement. DeVry is committed to encouraging a culture where all colleagues are comfortable asking legal, policy, compliance, and ethics questions, raising concerns, and reporting suspected wrongdoing without fear of retaliation everywhere we operate. III. Scope. This policy applies to all colleagues of DeVry, everywhere we operate. IV. Key policy definitions. Not applicable to this policy. V. Related Policies and Additional Resources. 1. DeVry Education Group s Code of Conduct and Ethics 2. Compliance Policy C-18, Compliance Case Management and Investigations 3. Ethics and Compliance Services HelpLine and HelpSite VI. Policy Requirements A. Duty to Speak Up In addition to knowing the legal and policy requirements that apply to your job and complying with them, you are expected to ask legal, compliance, and ethics questions, to raise concerns, and to report suspected wrongdoing if, You are unsure about the correct course of action and need advice You believe that an colleague or someone acting on behalf of DeVry is doing or has done something wrong You believe that you, yourself, have been involved in misconduct We work hard to promote a culture where colleagues are comfortable asking question and raising concerns. When in doubt, remember that the most important thing is that you Speak Up. 3

4 B. Where to go with questions and concerns Whenever you have a legal, compliance, policy, or ethics question or concern, you are encouraged first to speak with your manager. Many questions or concerns can be successfully addressed through face-to-face conversations between you and your manager. Establishing closer working relationships between managers and colleagues, with regard to compliance and ethics, is one of the objectives of this policy. However, if you are not comfortable bringing your question or concern to your manager, or if you have done so and not received a satisfactory answer, you have several other options. You may also contact, Your manager s manager Your local or divisional human resources representative The head of your functional area or division The DeVry Education Group s Chief Regulatory Officer The DeVry Education Group s Vice President, Audit, Ethics and Compliance Services A member of the DeVry Education Group s Legal team DeVry Education Group s Chief Executive Officer Alternatively, if you wish to remain anonymous, you may also report your question or concern to our toll-free compliance and ethics phone line known as the Ethics and Compliance Services HelpLine, or the web-based version of the HelpLine known as the Ethics and Compliance Services HelpSite. C. Zero tolerance with regard to retaliation DeVry seeks to promote a culture where colleagues are comfortable asking questions and raising concerns, without fear of retaliation. While we cannot guarantee that a colleague will not be retaliated against for raising a concern in good faith, we will not tolerate retaliation of any kind against an colleague who, in good faith, asks a question or raises a concern. Retaliation can mean many things. Examples can include, but are not limited to, Wrongful termination Failure to have an annual review conducted Being ostracized, treated unprofessionally, or removed from project teams Having information critical to the performance of your job withheld from you Having unrealistic expectations or requirements placed on you Colleagues who engage in retaliatory conduct are subject to disciplinary measures, up to and including termination of employment. D. Zero tolerance with regard to bad faith allegations One of the objectives of the Speak Up program is to help identify in a constructive way areas where we can improve our working environment and operations. For this reason, you are encouraged to come forward with legal, policy, compliance, and ethics questions; however, we recognize that such an open operating environment can also be used for nefarious or ill-intended gain. As such, we will not tolerate claims or allegations made in bad faith by any colleague against another colleague. Examples of bad faith allegations include making false statements related to the legal, policy, compliance, or ethical misconduct of another colleague. 4

5 It is important to recognize, too, that repeated reporting, or reporting on matters that are irreconcilable with the scope of your job or your job responsibilities, can actually have a detrimental impact or destructive effect on our working environment. Use good judgment when Speak Up. DeVry will not tolerate concerns or allegations that are raised in bad faith. Colleagues confirmed to have made an allegation against another colleague in bad faith are subject to disciplinary action, up to and including termination of employment. E. The Ethics and Compliance Services HelpLine and HelpSite Most compliance and ethics situations can be resolved by speaking directly with your manager, your manager s manager, or the head of your function or educational institution; however, if you are unsure about where to go, if you are uncomfortable about raising your concern with any of the resources listed above, or if you wish to ask your question or raise your concern anonymously, you may contact DeVry s Ethics and Compliance Services HelpLine or HelpSite. 1. The Ethics and Compliance Services HelpLine DeVry s Ethics and Compliance Services HelpLine is a toll-free phone reporting system that is available 24-hours a day, seven days a week, every day of the year. It is available to all DeVry colleagues. When you call the HelpLine, you are actually calling an independent third party service provider, completely independent of DeVry. The independent HelpLine vendor provides local-language operators, when necessary, so you are encouraged to utilize the HelpLine in your native language. When you call the HelpLine, a call specialist will answer your call and make a detailed summary of your question or concern. Your voice is never recorded, and you have the option to remain anonymous if you wish. All calls are given a special reference number, and you will be encouraged to call back within a specified time to check on the status of your matter. 2. The Ethics and Compliance Services HelpSite The Ethics and Compliance Services HelpSite is the web-based version of the HelpLine. It is made available to colleagues who are more comfortable asking question or raising concerns through the web. As with the HelpLine, when you access the Ethics and Compliance Services HelpSite, you are actually leaving DeVry s network entirely and asking a question or raising a concern on an independent third party s system. And as with the HelpLine, you have the ability to enter your question or concern in your native language and to remain anonymous if you wish. All reports entered through the Ethics and Compliance Services HelpSite is given a reference number, and you will be encouraged to follow up within a specified time to check on the status of your matter. 5

6 F. Protecting your anonymity and confidentiality Anonymity. Whether you use the HelpLine or the HelpSite, you are provided the opportunity to remain anonymous. If you chose to remain anonymous, DeVry will be unable to know the identity of the colleague who raised the concern. However, while your identity will remain entirely unknown to DeVry, it is important to understand that in some cases our ability to review or investigate a compliance or ethics matter will be hindered or limited, should the reporting colleague chose to remain anonymous. Confidentiality. Every effort will be undertaken to protect the confidential nature of your concern, to the extent possible, given our need to review, investigate, or resolve a matter, and our need to comply with the law. G. What happens after I Speak Up? If you have a legal, policy, compliance, or ethics question or concern, you are encouraged to speak with your immediate supervisor first. If, however, you are unable or unwilling to speak with your supervisor, you have many other options, described above. Regardless of which Speak Up option you chose (see the list of options above), your question or concern will be logged into our Ethics and Compliance Services Case Management System, which is operated by the same third party that operates the HelpLine and HelpSite. The information related to your question or concern will be categorized in our case management system based on the nature of concern, prioritized based on the severity of your concern, and then assigned to the appropriate person for review and handling. 6

7 Ethics and Compliance Services HelpLine Numbers Bahamas Brasil Canada Dominica Hong Kong St Kitts United States Ethics and Compliance Services HelpSite Security For campus security matters, call the See Something, Say Something hotline:

8 Q: What is the Speak Up program? Frequently Asked Questions A: Speak Up is part of our Ethics and Compliance Services program, and is designed to continue to encourage a workplace where colleagues are comfortable asking questions, raising concerns, and reporting suspected wrongdoing, without fear of retaliation. Q: I have a legal, compliance, or ethics question. What should be my first step? A: You are encouraged first to speak with your immediate supervisor about any legal, policy, compliance, or ethics question or situation. If, after doing so, or if you re not comfortable speaking with your manager, you have several other options, which are set forth in this policy. Q: I have feedback that I would like to provide with regard to a recent DeVry event or colleague communication. Where should I send it? A: The resources identified in this policy are to be utilized for compliance and ethics questions or concerns. You should submit feedback or any other non-compliance-related question or issue to the appropriate person or resource. Q: I have brought a concern forward in good faith, and now I suspect I am being retaliated against by my manager and co-workers. What should I do? A: DeVry has a zero-tolerance policy against retaliation. You should report your concern to one of the resources listed in this policy. Q: I have reported a concern to the HelpLine or HelpSite, but who will actually review the matter? A: Which business leader actually reviews and handles your matter depends on the nature and priority of your concern. Employee relations matters, for instance, are usually handled by local, regional, or divisional human resources representative. 8