Compliance & Ethics

In accordance with Texas law and HCC Board policy, retaliation or reprisals against individuals who file good-faith complaints is prohibited. Retaliation against individuals and witnesses who participated in an investigation is also prohibited.

 

In all cases, reports will be handled as confidentially and discreetly as possible to the extent allowed by law, with facts made available only on a need-to-know basis to ensure a proper investigation and resolution. When reporting a complaint, the reporter may choose to remain anonymous. As noted below, choosing to remain anonymous may limit HCC’s ability to fully address the reported concern.   

In cases in which the reporter has requested anonymity, the individual(s) accused of wrongdoing in the report will not receive a copy of the complaint.  In order to properly investigate the matter, however, it may be necessary to interview the accused individual and inform the individual about the filing of a complaint. In some circumstances, information regarding a complaint could become available under the Texas Public Information Act (Texas Government Code Chapter 552).

Unless the information relates to an individual who consents to disclosure of the information, the following are confidential:

1. Information that directly or indirectly reveals the identity of an individual who made a report to the compliance program office of an institution of higher education, sought guidance from the office, or participated in an investigation conducted under the compliance program; and
2. Information that directly or indirectly reveals the identity of an individual as a person who is alleged to have or may have planned, initiated, or participated in activities that are the subject of a report made to the compliance program office of an institution of higher education if, after completing an investigation, the office determines the report to be unsubstantiated or without merit.

 

Information is excepted from disclosure under the Texas Government Code, Chapter 552, if it is collected or produced in a compliance program investigation and releasing the information would interfere with an ongoing compliance investigation.

Information that is confidential or excepted from public disclosure may be made available to the following in compliance with applicable law and procedure:

1. A law enforcement agency or prosecutor;
2. A governmental agency responsible for investigating the matter that is the subject of a compliance report, including the Texas Workforce Commission civil rights division or the federal Equal Employment Opportunity Commission; or
3. An officer or employee of an institution of higher education who is responsible under institutional policy for a compliance program investigation or for reviewing a compliance program investigation.

 

Complaints arising out of an event, or related events, shall be addressed in one complaint. Individuals shall not file separate or serial complaints arising from any event or series of events that have been or could have been addressed in a previous complaint.

When two or more complaints are sufficiently similar in nature or the remedy or remedies sought in multiple complaints overlap, in order to permit their resolution in the most efficient manner possible, the Compliance Department may consolidate the complaints at its discretion.

In addition, if the subject of a Hotline report was previously investigated and addressed by another HCC department under other established processes, the report is subject to dismissal.

 

HCC recognizes that, in rare instances, an individual might misuse the Hotline to disrupt operations or to humiliate or harass others. Employees and students who intentionally or knowingly file false complaints or who demonstrate a pattern of filing complaints without a good faith basis may be subject to disciplinary action up to and including termination or expulsion. Additionally, these complaints are subject to dismissal by the Compliance department. However, before disciplining an employee or student based on an allegation of bad faith or false statements, the appropriate administrator, in consultation with the Office of General Counsel, will carefully evaluate the evidence and provide the employee or student an opportunity to respond to the allegation.

Good faith allegations that ultimately are not substantiated will not result in discipline under this provision.

The definition of retaliation under this procedure excludes disciplining a person for filing a bad faith or false complaint.

 

When submitting a report to the Hotline, it is important to provide sufficient detail for HCC representatives to be able to investigate the allegations presented.  To the extent available, it is helpful to include a detailed narrative with details such as full names, specific locations, times, and dates with your initial report.

If the report submitted lacks sufficient information to proceed with an investigation, the Compliance Department will attempt to contact the reporter through the EthicsPoint portal and other contact method, if provided upon the time of the report. If no response to the request for additional information is received after 15 College business days, the case may be closed for insufficient information.

 

When a report is submitted to the Hotline, the Compliance Department conducts an initial review and analysis of the allegations in the report. Concerns that are not related to occupational fraud, waste, and abuse, or ethical violations may be referred to the appropriate department(s) based on the subject area of your concerns to be investigated under the processes established by Board policies and regulations.  Please review the section titled Reporting Other Concerns for more information.

 

Employees, students, and members of the public are encouraged to report concerns regarding occupational fraud, waste, abuse, and ethical violations to the Hotline.

 

The Hotline may be used to report a wide range of fraud, waste, and abuse, or ethical violations. Examples of prohibited conduct include, but are not limited to, the following:

• Theft or misappropriation of property, supplies, funds, or resources
• Forgery or alteration of time records, salary records, benefits records, and other employment records
• Forgery or alteration of reimbursement records, financial records, and purchase orders
• Forgery or alteration by employees of student-related records such as grades, transcripts, or scholarship or tuition documents
• Illegal or fraudulent handling or reporting of money transactions
• Authorizing or receiving compensation for goods not received or services not performed
• Acceptance or solicitation of any gift, favor, or service that might reasonably tend to influence the employee in the discharge of their official duties
• Destruction or disappearance of records, furniture, fixtures, or equipment where theft is suspected
• Bribery or attempted bribery
• Misuse of authority for personal gain; self-dealing
• Reckless disregard of environmental laws or safety rules
• Using HCC property or resources in a manner that is careless, reckless, or unnecessarily wasteful.

 

Reports submitted to the Hotline via the website and telephone are entered directly into the EthicsPoint secure server to prevent any possible breach in security. The Hotline reports are only made available to specific individuals within HCC who are charged with evaluating and following up on the report, based on the type of violation and location of the incident. These personnel have received training regarding the confidentiality of the reports.

Within 3-5 College business days, a member of the Compliance Department conducts an initial review and analysis of your report and may contact you with follow-up questions.

After you submit your report to the Hotline, you will be assigned a unique code called a "report key." Write down your report key and password and keep them in a safe place. Without your report key and password, you will not be able to access your report. After 5-6 College business days, use your report key and password to check your report for status updates, to add more detail, or to answer questions about your report asked by an HCC representative.  If you reported anonymously, this will be the way you can continue an anonymous dialogue with an HCC representative.

 

Yes, by reporting you are bringing areas of concern to the attention of the administration which can be addressed to ensure compliance with the law or policy and to take corrective action as may be needed.

When in doubt, when unsure where to go, or when you prefer to remain anonymous, EthicsPoint is always available, and we encourage you to report.