Trust the Leaders 2.0 Volume 4

Page 38

Internal Investigations

Internal Investigations at Institutions of Higher Learning: FAQs by Parker Sanders

1. What types of events trigger internal investigations at institutions of higher learning?

it very well may be that institutions face a greater likelihood of needing to conduct an internal investigation than for-profit entities of similar size.

Institutions of higher education often employ thousands of employees and may enroll tens of thousands of students. These people may use campus housing, work on government research grants, or interact with others inside or outside the classroom, lab or athletic field. Institutions have commercial relationships with suppliers and customers beyond the students they educate. Numerous federal and state regulations apply to institutions. These regulations become increasingly complicated every year, and the cost for noncompliance is high. Many institutions also operate on the international stage – oftentimes sending researchers and students to developing countries around the world. Despite the concept of an ivory tower, the reality is that their faculty, employees and students are not immune from the lure, or appearance, of bad acts.

A few areas that could trigger an investigation at an institution, if they were to arise, could include conduct predicting violence (perhaps a mass shooting), inappropriate conduct involving students or subordinates (now or years ago), improper handling of government contracts or grants (which might involve false statements), embezzlement or theft, bribery (especially in developing countries), privacy issues, conflicts of interest, state ethics laws, discrimination issues (for instance, EEOC claims or Title IX investigations), sports controversies or violations of rules and regulations concerning athletics (arising from, for instance, the NCAA and, here again, Title IX), and perhaps healthcare or immigration issues. The occurrence of any of these situations, or merely an alleged occurrence, particularly in athletics, can cause enormous damage to an institution’s brand, which is its greatest asset and can take years to heal.

So, because the scope of operations is broad and the applicable laws and regulations are many,

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