Whistleblower and Ethics Reporting

I. PREAMBLE

Atlas University regards honesty as sacred law and transparency as a moral discipline.
Every member of this institution—student, employee, trustee, or contractor—is a steward of the University’s moral and financial integrity.
This Policy ensures that any person may report wrongdoing without fear of reprisal, so that righteousness and truth remain the pillars of the Atlas covenant.

II. PURPOSE

This Policy establishes procedures and protections for individuals who in good faith report:

  1. Violations of law or regulation.

  2. Fraud, waste, or misuse of University funds or property.

  3. Gross mismanagement, abuse of authority, or unethical behavior.

  4. Retaliation against any person who reports such conduct.

It affirms the University’s commitment to accountability and compliance with all state and federal standards.

III. ADMINISTRATIVE AUTHORITY

PresidentOverall responsibility for ethical governance.General CounselOversees investigation and legal compliance.Director of Human Resources (HR)Manages personnel-related complaints.Chief Financial Officer (CFO)Handles financial misconduct reports.Chair, Audit and Integrity Committee (AIC)Receives confidential reports involving senior officers or the President.

The Office of Institutional Integrity (OII) serves as the central intake and coordination point for all reports under this Policy.

IV. POLICY STATEMENT

Atlas University strictly prohibits retaliation against any individual who, in good faith, reports suspected misconduct or participates in an investigation.
All reports will be handled promptly, fairly, and confidentially.

V. SCOPE

This Policy applies to:

  • All employees, faculty, administrators, trustees, students, vendors, and contractors.

  • All aspects of University operations, including academics, finance, research, and facilities.

VI. REPORTABLE CONDUCT

Examples include, but are not limited to:

  1. Fraud, theft, embezzlement, or falsification of records.

  2. Violation of laws or regulations (state, federal, or accrediting).

  3. Conflicts of interest or unethical procurement.

  4. Sexual harassment, discrimination, or retaliation.

  5. Unsafe practices endangering health or safety.

  6. Misuse of donor funds or grant money.

  7. Academic dishonesty or data fabrication.

VII. REPORTING PROCEDURES

1. Methods of Reporting

Reports may be made:

  • Directly to a supervisor, department head, or HR.

  • Through the Office of Institutional Integrity (in person, by email, or phone).

  • Anonymously via the Atlas Integrity Portal.

2. Content of Report

Reports should include:

  • Description of alleged misconduct.

  • Dates, individuals involved, and evidence if available.

  • Reporter’s name and contact (optional for anonymity).

3. Acknowledgment and Initial Review

The OII will acknowledge receipt within five (V) business days, determine jurisdiction, and assign an investigator or refer to appropriate office.

VIII. INVESTIGATION

  1. Investigations will be impartial, confidential, and completed within thirty (XXX) business days when possible.

  2. The investigator may interview witnesses, review records, and consult relevant offices.

  3. Findings and recommendations shall be submitted in writing to the President or appropriate authority.

  4. Disciplinary or corrective actions will follow the relevant University policies.

IX. CONFIDENTIALITY

All information disclosed under this Policy shall remain confidential to the fullest extent possible, consistent with the need to conduct a fair investigation.
Disclosure is limited to individuals with legitimate involvement in the process.

X. PROTECTION AGAINST RETALIATION

  1. Retaliation against any person for making a good-faith report or participating in an investigation is strictly prohibited.

  2. Retaliatory acts include dismissal, demotion, threats, harassment, or discrimination.

  3. Allegations of retaliation are investigated as separate offenses under this Policy.

Individuals found to have engaged in retaliation shall face disciplinary action up to and including termination or expulsion.

XI. FALSE CLAIMS

Reports made maliciously or in bad faith will result in disciplinary measures.
However, a report made in good faith—even if unsubstantiated—will never result in punishment.

XII. RECORDKEEPING

All reports, investigations, findings, and resolutions are retained by the Office of Institutional Integrity for a minimum of seven (VII) years, in accordance with the Records Management and Legal Compliance Policy.

XIII. TRAINING AND AWARENESS

  1. Annual Whistleblower and Ethics training for all employees, administrators, and trustees.

  2. Orientation modules for new hires and students.

  3. Posters and online materials reminding the community of reporting channels and protections.

XIV. ETHICAL AND SPIRITUAL FRAMEWORK

Truth is the highest act of loyalty.
Atlas University teaches that integrity requires courage—to speak when silence would be complicity.
Reporting wrongdoing is not rebellion but righteousness, preserving the sanctity of learning and the purity of trust.

XV. REVIEW AND AMENDMENT

This Policy shall be reviewed annually by the General Counsel and Audit and Integrity Committee, approved by the President, and ratified by the Board of Trustees.