Whistleblowing Compliance Reporting Hotline

The willful and intentional taking of money or property by a person who has been entrusted with the money or other assets for that person's own use or gain.

Rules establishing a regulatory and supervisory framework and consumer and investor protection in the Union's financial services and capital markets, banking, credit, investment, insurance and re-insurance, occupational or personal pensions products, securities, investment funds, payment services and the activities listed in Annex I to Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms.

The deceitful practice of obtaining money or property through intentional use of false pretenses, false documents or misrepresentation. An illegal conversion of assets or property of value to one's own use.

The deceitful practice of obtaining money or property through intentional use of false pretenses, false documents or misrepresentation, specifically related to government contracts, projects, funding, or other government-related business.

Side agreements (also called side letters) are undisclosed verbal or written contract terms not included in the signed contract. Examples of side agreements include: extension to payment terms; promises of future discounts or pricing; free or abnormally high discounts on additional products or services; return rights or early termination rights; free upgrades.

The illegal taking of property belonging to someone else without consent. The intent is to permanently deprive the owner of property and then use this property as one's own.

Any type of theft related to institution finances, property, assets, vendor or customer assets or property or any other unauthorized use of such institution property or assets.

The purposeful, unethical or questionable recording of accounting or auditing matters. Examples may include: fraud; deliberate errors related to financial statements; noncompliance with accounting controls; misinterpretations or false statements to or by senior officers regarding financial records; or deviation from full and fair reporting of the company's financial condition.

Discussions or agreements with competitors about process of credit terms, submission of bids or offers, allocation of markets or customers, restrictions on production, distribution or boycotts of suppliers or customers that would result in monopolization of anticompetitive markets.

Purposeful and methodical documentation and examination of any business or financial transaction that is related to GAAP.

The offering or acceptance of money or other incentives to persuade someone to do something, especially something illegal or unethical.

Providing false information on, or making any unauthorized changes to, any financial documentation, reporting information, or documentation presented to or relied upon by the organization to conduct its affairs or to report its financial results.

Careless, unlawful or fraudulent conduct in recording, preparing, reporting or disclosing of either the value or the content of a contract, report, statement, document, record or electronic file.

The unauthorized or illegal use of the company's intellectual property rights to include but not limited to copyrights, patents and trade secrets

Inappropriate or unauthorized use of company resources and/or property.

Any issues raised by a vendor of the organization for transmission to the Lead Director or to all the Independent Directors of the organization regarding improper or unethical vendor relations.

Violation relating to the organization's code of conduct.

Reporting of any suspected violation of the Foreign Corrupt Practices Act of 1977 (FCPA), including the offer or payment of anything of value to a foreign official, foreign political party, or candidate for political office, for the purpose of influencing any act of that foreign official in violation of the duty of that official, or to secure any improper advantage in order to obtain or retain business.

A situation where a person in a position of trust has competing professional or personal interests which can make it difficult to impartially perform the assigned job duties.

A conspiracy to engage in and conduct illegal, unethical and grossly inappropriate behavior at a corporate level.

Unauthorized and unlawful disclosure or misappropriation of corporately owned intellectual property or trade secrets and other "confidential information," including but not limited to corporate, employee, competitor and customer information; marketing and other corporate databases; and business plans.

Providing false information on, or making any unauthorized changes to, any institutional documentation, reporting information or documentation present to or relied upon by the institution that do not involve the financial reporting, accounting or bookkeeping of the institution.

The illegal duplication and/or distribution of patented, copyrighted or licensed products or property for commercial gain.

Violations of the Company’s Information Security Policies, Code of Computer Conduct, Acceptable Use, etc., that govern conduct while using the company network or confidential information resources.

The use of electronic communication to bully a person, typically by sending messages of an intimidating or threatening nature.

Fraud that involves someone pretending to be someone else in order to steal money or get other benefits. The use of another person's identity for personal gain.

Improper disclosures over the Company’s computer network, such as posting confidential information to websites, the sending or receipt of harassing or threatening emails, etc.

Concerning the processing of personal data and the protection of privacy in the electronic communications sector, protection of natural persons with regard to the processing of personal data and on the free movement of such data, measures for a high common level of security of network and information systems across the Union.

Failure to meet requirements as defined by Equal Employment Opportunity Commission (EEOC) or American Disability Act (ADA) (examples include nepotism, proper disability access).

Improper, misleading or deceptive actions/statements, falsification of records, or misrepresentation of actual conditions related to institution benefits plans, including health and supplemental insurance plans, tuition benefits, and sick or other paid time-off programs.

The illegal or inappropriate use of drugs or alcohol, whether purchased legally (prescription) or illegally (street drugs). Substance abuse is also the misuse of any substance, whether controlled by Federal law or not, such that when put into one's body it is contrary to the substance's intended use. Examples may involve the use of alcohol, marijuana, narcotics, amphetamines, depressants, stimulants, aerosol sprays (inhalants), hallucinogens or prescription drugs.

Words or actions of an unlawful intent, which can be clearly expressed, hidden, and/or veiled, that threaten to inflict bodily harm on someone or someone's property and are made to intimidate, terrorize, frighten, harass, taunt, bully or coerce. A threat of violence can also be made in order to extort favors, influence, or anything else of value from the target of the threat.

The workplace contains conditions where employees may be injured or killed, or their short-term or long-term health may be adversely impacted. These conditions could be caused by a worker, a team of workers, negligence, or by company policy. Examples may include: poor lighting; unstable storing of materials; exposure to hazardous materials; excessive noise; lack of protection; needless exposure to dangerous machinery; lack of protective clothing; or lack of physical security.

Any instance in which an employee has exhibited inappropriate behaviors or engaged in conduct that compromises the safety of all of those concerned. An outward demonstration by an individual with the objective to impose harm, injury or damage to person(s) and/or their property.

An employment termination which breaches one or more terms of the condition of employment, company policy or employment law.

The submission of a false, misleading, or fraudulent application for admission and/or supporting documents to the university. Examples include suspicion of altered transcripts, forged recommendations, and failure to list all courses taken. Honest mistakes in transcribing grades or other errors caused by carelessness would not be considered an irregularity.

Violations of the rules of the National Collegiate Athletic Association (NCAA) regarding recruitment of student athletes; attempts to influence the outcome of sporting events (such as gambling or wagering by student athletes or staff); the misuse of assets, financial aid or scholarships; or other academic violations defined within the NCAA rules.

FERPA is a federal law that protects the privacy of student's educational records and applies to all educational institutions that receive funds under any program administered by the Secretary of Education. Generally, a violation occurs when student information from educational records is released without written permission from the student.

The misuse of power, authority, or control related to one's position in the organization. Examples include but are not limited to: directing employees to perform non-organization related work; causing employees to work overtime without compensation; or using organization assets for non-organization business without proper permission.

An act that defies decent behavior or a governing principle. Activities not conforming to or in accordance with established conduct of right and wrong, violations of a rule, regulation, law, operating procedure, past practice or protocol (for example: bribery, COI, intellectual property, regulatory, privacy, HIPPA, FCPA and other third-party/vendor/customer issues).

An act that defies decent behavior or a governing principle. Activities not conforming to or in accordance with established conduct of right and wrong and moral character.

The use of inflammatory, derogatory, unduly critical or insulting communication to a staff person, faculty, administrator, alumni or student.

Failing to prohibit unauthorized access to the Organization's assets (including intellectual property) or failing to ensure efficient use of such Organization's assets.

The willful, malicious, reckless, and deliberate damage, destruction or defacing of private or public property. The emphasis is on a act against property, not people.

A worker who is wasting time, is "goofing off" and purposely not working while on-the-clock and being paid, or is being told by a supervisor to perform work that clearly has no benefit to the company.

Calculated and/or intentionally unlawful and unethical behavior. Misconduct can be any conscious attempt to infringe a statute or norm.

Please use this incident type if you do not feel that the provided list of incidents describe the activity on which you are making a report.