Protocol for Reporting Concerns Related to the Just Employment Policy

Georgetown University encourages University employees and contract employees to address concerns related to the Just Employment Policy through regular channels, such as speaking with their supervisor. Non-union University employees also may use the dispute resolution procedures outlined in Section 303 of the University’s Human Resources Policy Manual. Unionized University employees and contract employees can report concerns through their collective bargaining agreement grievance procedures. Non-union contract employees can report concerns through their employer’s grievance procedures.

In addition, the Georgetown Compliance Helpline provides a confidential, and if desired anonymous, way to report problems or raise concerns, including those related to the Just Employment Policy. The Helpline does not replace employer-provided or negotiated grievance procedures, but provides a mechanism for reporting problems when an individual is uncomfortable using ordinary procedures or when a previously reported issue has not been addressed. Individuals may make reports through the Compliance Helpline, or by dialing (888) 239-9181. When reporting a problem through the Compliance Helpline, please indicate that the report is related to the Just Employment Policy.

The Just Employment Policy does not cover all employment disputes but does cover such issues as the failure to pay accurate and timely wages, unsafe working conditions, harassment, infringement of employees’ right to freely associate and organize, and denial of equal access to Georgetown’s community resources.


Protocol for Reports Related to Contract Employees Covered by the Just Employment Policy

1. The University receives a report about a potential Just Employment Policy (JEP) violation made by, or on behalf of, a contract employee who is covered by the JEP.  Reports will most commonly be received via the Georgetown Compliance Helpline or through communication to the chair of the Advisory Committee on Business Practices (ACBP), but may also be received through other channels.

2. When a report comes into the Georgetown Compliance Helpline, the Associate Vice President (AVP) for Compliance and Ethics:

3. When the chair receives a report referred from the AVP for Compliance and Ethics or from another source, the chair:

  1. to gather and confirm the details of the report; and
  2. to inform the reporter that the University will endeavor to keep the reporter’s identity confidential to the extent possible during the process of reviewing the report;
  1. seeks information that will allow the chair to contact the contract employee directly and make contact if possible;
  2. informs the source of the report, and the contract employee if contacted, that the University will endeavor to keep the reporter’s identity confidential to the extent possible during the process of reviewing the report; and
  3. gathers details regarding the report, including documentation if possible.

4. The chair notifies relevant University officials, including the contract manager and colleagues from the Office of General Counsel and the Division of Financial Affairs, and the ACBP that a report has been received. The chair will notify the ACBP within a reasonable time after an action is taken in situations in which prompt action is necessary (e.g., a situation involving a threat or other immediate concern about the safety or welfare of a contract employee).

5. The chair meets with the ACBP to explain the nature of the report.  The ACBP discusses the matter and advises the chair on the types of information or evidence that it thinks might be helpful to determine the validity of the report.

6. The chair and relevant University officials discuss the report and determine the appropriate next steps, which may include:

7. The contract manager communicates with the employer to:

8. The chair and relevant University officials examine the evidence from the reporter, the employer and other sources, and consult with the ACBP.

9. The chair and relevant University officials then assess whether the situation requires further review.

10. If the employer does not resolve the report in a manner satisfactory to the University, the University considers additional steps, which could include requesting that the employer retain an independent expert from a list of University-approved organizations to conduct an investigation, or terminating the contract.

To report a concern related to the Just Employment Policy, visit the GU/EthicsPoint Compliance Helpline or call (888) 239-9181.