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:

• determines the nature of the report to see whether it might fall under the provisions of the Just Employment Policy (if the AVP is uncertain whether the report falls under the Just Employment Policy, the AVP contacts chair of the ACBP to discuss the report);
• if the reporter identifies him/herself in the report, contacts the reporter to gather relevant information relating to the report, including the reporter’s contact information;
• informs 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;
• informs the reporter that the report and related information (including the reporter’s identity) will be given to the chair; and
• promptly passes along the report and related information to the chair.

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

• when the reporter’s identity is known, contacts the reporter directly and in a timely manner (with the assistance of a translator, if necessary):

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;

• in cases in which the report has come from someone other than the contract employee who may be subject to a violation of the JEP (for example, a student or other person who makes a report on a contract employee’s behalf):

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:

• requesting that the employer provide documentation so that the University can determine the validity of the allegations in the report;
• asking the employer to allow the chair to hold separate training sessions on the JEP for the employer’s managers and employees at which employees would be reminded of the provisions of the JEP, and would be informed that they can report concerns related to the JEP to the chair during the meeting or privately after the meeting, and could, to the extent appropriate, be informed that a report relating to their employer has been received; or
• other steps as may be appropriate.

7. The contract manager communicates with the employer to:

• explain that a report has been received;
• explain that in order to determine whether there has been a JEP violation, the University needs to review the allegations in the report;
• request that information or documentation be provided, seek permission to conduct training or provide employees with information on the JEP, or ask that other appropriate action be taken;
• remind the employer that the University guarantees a safe and harassment free workplace for all employees on campus, including contract employees, and, therefore, it will not permit intimidation of employees during or after the report review process; and
• inform the employer that the University will continue to communicate with the employer as the report review process moves forward.

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.

• If no further review is needed, the contract manager notifies the employer and the chair notifies the reporter of the University’s determination.
• If further review is needed, the contract manager explains to the employer the actions the University expects it to take to resolve the report and provides a reasonable amount of time for the employer to take those and other actions.

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.