A Compliance Case Study

The People:

Ethan, an employee in the Admissions Office at the university

LaTonya, another employee in the Admissions Office, and Ethan’s teammate 

Roger, their team leader

The Scenario:

“This is the definition of ‘toxic environment’,” Ethan thought, as he sat through the monthly meeting of the Admissions team. He was thinking how nice it would be to work from home.

Roger, their team leader, was on another one of his rants: “I mean, why are so many of them applying?” he asked, speaking about some recent applicants who had DACA status. These students, who had been brought into the United States illegally when they were children, were protected under the DACA (or Deferred Action for Childhood Arrivals) policy. “And next,” Roger continued, “they’ll be applying for financial aid, taking funds away from students who are US citizens and others who came here legally.”

“You know what else?” Roger went on. (“Boy, he’s on a roll today,” Ethan sat thinking). “The person in charge stinks at her job! What we need are more white males who are in charge. I mean, to have a minority in charge, who’s also a woman??? That’s like a double whammy!”

“Is he even hearing himself? Does he expect us to agree with him?” Ethan wondered. He looked at the faces of his teammates at the table; they were shocked and silent.

It was a well-known fact that Roger was often out of line with his comments, which were usually discriminatory in nature. Some of the team had approached management to voice concerns, but while they seemed to take the complaints seriously, nothing changed.   

After the meeting, Ethan noticed that he had a new chat message. It was from LaTonya, an African American woman on his team. “Hey Ethan. I’m sitting here, once again, not believing what I just heard. Today our “leader” crossed a line for me.”

“I know,” Ethan wrote back. “I’m sitting here trying to decide what to do.”

“Can I come see you?” LaTonya asked.

“Sure,” Ethan replied.

A moment later he heard a knock on his door. “Listen. Some of us are planning to stage a walkout, as a protest, at lunchtime. People have to know how bad it is here. Management hasn’t done anything about it, so we have to. That man should not be allowed to hold a position at a public university that prides itself on diversity.”

Ethan listened and he agreed with what LaTonya was saying. But he worried that his teammates had not thought through the whole walkout scenario. What would happen if the Admissions Office had to shut down because the staff had walked off the job? They were in the “busy” season, too, processing thousands of applications from potential students. What if their protest held-up the admissions process for some of the very students Roger had ranted about?

“Okay, listen,” Ethan said, “I agree with everything you’re saying. Roger’s views have no place in our office or at the university. But, I don’t think a walkout is the best way to handle this. What if everybody who was just in that meeting called the Helpline to report the behavior? Management would have to listen if a formal investigation into Roger’s conduct was opened.”

Roger and LaTonya agreed to file a report, and they asked others on the team to do the same. The Helpline received multiple reports of Roger’s conduct during the meeting. When the Integrity and Compliance Office approached Roger to say they were conducting an investigation into his reported behavior and to schedule a time to interview him, he submitted his letter of resignation.

The Takeaway

Ethan and LaTonya were right. Roger was out of line and his comments had no place in their office or at the university. Not only was he stereotyping certain students and speaking about them in a derogatory way, but Roger exhibited bigotry and misogyny while speaking about university leadership. None of these traits are espoused by VCU; in fact they are the opposite of these values from the Code of Conduct, echoed in the Expectations of Ethical Conduct Policy:

Respect – We respect individuals, diversity and the rights of others.

Individuals are expected to treat everyone in the VCU community with respect. This means prioritizing professionalism and civility and not engaging in behavior that could be reasonably viewed as harassing, hostile, intimidating or disrespectful and refraining from using offensive or inflammatory or aggressive language.

Managers and supervisors have the additional responsibilities to:

Be a professional role model and support team members by: Facilitating or fostering an environment that is inclusive and respectful…

VCU Expectations of Ethical Conduct Policy

Ethan, LaTonya and their teammates did the right thing by contacting the VCU Helpline. Ultimately, Roger decided to leave rather than face an investigation into his conduct, but his departure is telling. Often, bad actors know when they’ve been caught; Roger probably sensed that no one wanted to “follow the leader” anymore.


Please note: The names, details and business unit mentioned in this case study have been changed to protect the people involved in the actual case investigated by the ICO.

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