Compliance Corner – Issue 3.6
2 MORE VIDEOS! This month, we follow two more characters from the original annual ethics and compliance training – Dr. Evans’ administrative assistant, Carol, and the subject of the investigation, Dr. Evans herself. Learn how each of them responded to the allegations about Dr. Evans’ behavior.
As we come to the end of Fiscal Year 2024, we bring you a few words from our Chief Ethics and Compliance Officer, Suzanne Milton.
FY 2024 has been quite a journey. As we start fresh in FY 2025, here are a few thoughts from our neck of the woods in the Integrity and Compliance Office:
+Workplace culture matters to each of us, and we build it together. Our Psychological Safety workshops involving over 400 VCU employees in 15 departments or schools focused on key skills to building a positive culture. Our team learns from each session.
+We asked you about integrity at VCU. You spoke and we listened. The results from the 2024 VCU Integrity Survey are in, and we will share them with you in early FY25. One of the big takeaways was that 85% of respondents felt that their immediate supervisor was a good role model, but only 60% felt the same way about senior leadership. It’s our job to determine why there is such a large discrepancy here, and to figure out how we can help to bridge that gap.
+Speaking up can lead to important discoveries-both opportunities and failures we need to address. Silence is risky. This year, VCU benefited from the timely and courageous speaking up of many individuals, whether in pointing out a compliance gap or raising questions about abusive behavior, these reporters helped VCU make changes and hold people accountable for acting in line with our values. We are not perfect, but we are making progress.
+Our students care about integrity, and we must continue to set a good example for them, especially when we disagree. It is a complex world, and doing and knowing what is right is not easy. But this is perhaps the most important thing our students can learn, and we must keep striving to be worthy of their trust.
+There is a strong sense of collaboration building at VCU. We appreciate the many partners on campus who have worked with us to eliminate silos and find productive solutions across functions and teams. Special thanks to Internal Audit, Human Resources, Technology/Information Security, Equity and Access Services, the Compliance Steering Committee, the Schools of Medicine, Nursing and Pharmacy and the VCU Police for your support and partnership.
Wishing all our partners and their families a summer full of fun.
Best,
Suzanne
Soliciting for Swimsuits: Staying smart when leading from the heart
A Compliance Case Study
The People:
Rahim, Tony and Katrina – Staff members in the School of Social Work
Dr. Rick Ward – Department Chair, School of Social Work
The Setting:
West Franklin Street, and Christian’s Pizza
The Event:
Rahim, Tony and Katrina were on their way to Christian’s Pizza to grab a quick lunch. Tony seemed to echo the thoughts of his teammates when he said, “I’m glad we’re grabbing some pizza today. Payday’s not ’til next week, but at least I can afford a slice!”
Katrina: Same! #gratefulforpizza.
Rahim: Speaking of money, did Dr. Ward hit you guys up for a donation, too?
Katrina: Yes! He did!
Tony: He must’ve hit all of us. Did he say it was for the kids at the community center?
Rahim and Katrina: Yes!
Katrina: I mean, I get it. He loves what he does and he has a big heart. And we all know how hard it is for some of the kids and families our students work with.
Rahim: …But…should you be hitting up your colleagues for the cash to help them out?
Tony: I know! And it was really awkward, because the way he asked, I felt cornered. He said something like, “Hey, listen, some of the kids don’t have flip-flops and swimsuits. Would you like to donate to a fund I started to help them get some summer clothes and beach towels and stuff for the pool?” I wanted to say yes, but I felt like he was crossing a line, somehow.
Katrina: That’s how I felt. He asked me right after we had our weekly check-in about student placements and he slid that into the conversation like it was part of the meeting, as well as an expectation. Of course, I’d like to help the kids and their families, but…
After they found a table and started eating, Rahim checked his phone to look at email. He said, “You are not going to believe this. Dr. Ward just sent an email asking the team to donate to his funds drive, and he provided his Venmo account info. You know, I bet he’s not even supposed to ask us for donations. Couldn’t that affect the relationship? Would he look at me more favorably as an employee if I donated? Would I get special treatment or better ratings at review time?
Tony: And would it affect us in a negative way, if we didn’t donate?
Katrina: (Sigh.) Okay, I have a confession to make. I actually did give Dr. Ward some money.
Tony: What?!
Rahim: How much?!
Katrina: Not a lot. Ten dollars. I had already told him that I didn’t have any money the first time he asked, but when he asked me at our next meeting, I was thinking it would just be easier to donate something. But now that we’re talking about it and how it could affect the manager-employee relationship, I’m concerned. I think I need to talk to someone.
The Takeaway:
Just imagine if everyone you worked with asked you for money for all of their different fundraisers and causes. Not only would this become a major distraction for the person doing the asking and the people considering making the donations, but it could potentially affect their relationships. And if one of the parties involved in that scenario was a direct report of the other person, there could be the appearance of an expectation that the person who donated would receive special consideration. Whether or not that’s true, if the donor later received a raise, a promotion, or some other benefit from the person who had solicited the donation, it could look like that happened as a result of the donation. And if the employees who didn’t contribute also didn’t receive raises, promotions or other perks, it might look like that was the result of their failure to contribute.
Fortunately, VCU has policies in place to help. The Conflict of Interest and Commitment Disclosure and Management for University Employees (Including Faculty) policy states that a conflict of interest exists when outside interests affect (or appear to affect) business decisions. Dr. Ward’s solicitation of his team members for the children at the community center, albeit genuine and well-intentioned, presents a conflict of interest because it could affect, or appear to affect, his management of the team. By soliciting his employees for money, he put them in the uncomfortable position of having to weigh how to respond, and wondering whether their participation or non-participation might affect their employment. Additionally, the Computer and Network Resources Use policy restricts the use of university computers and email to university-related actions. While his department works with the children and families at the community center, it was a personal project, and not an official VCU-sponsored program, that he established to raise funds for the children. Soliciting colleagues for his personal fundraiser using university computers and email violates this policy.
When Katrina raised questions about Dr. Ward’s fundraiser an investigation took place and he received sanctions, including written counseling and training on how to set-up a proper VCU-sponsored fund to help the children at the community center.
One of the best things about VCU employees is their willingness to help others. Sometimes your heart is in the right place, but you don’t know how to achieve the goals you have for helping others within the boundaries of the university’s ethical expectations and policies. When you have questions, ask. Better to learn the proper way to help others, like the kids who just want to have some summer fun, than to end up all wet.
Please note: This case study is based on an actual case investigated by the Integrity and Compliance Office. The identities of the people and department and the details of this case were changed to protect the people involved.
Have questions about anything in this month’s blog? Have ideas about what we could include in future posts? Please contact us at [email protected] – we’d love to hear from you!