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Student Safety

Operators Are Standing By: Hotline Reporting at Thunderbird School

New graduates of the Thunderbird School of Global Management in Glendale, AZ are challenged to sign a professional oath of ethics akin to the medical practice's Hippocratic Oath. But the graduate school knows that pursuing an ideal isn't the same as achieving it. Some students don't follow the rules. Some students do things that imperil their lives. And that's why Thunderbird has also implemented EthicsPoint, a Web-based anonymous hotline and case management system. Originally introduced in 2006 to allow faculty and staff to report incidents of unethical behavior, the college expanded the functionality in 2008 to all students as a safety measure.

By providing a means for a student to anonymously report concerns about another student, the service is part of overall behavioral intervention, explained James Scott, registrar and associate vice president of academic operations. With about 600 full-time residential students on campus from all over the world and a total student body of about 1,300, "we're smaller and closer-knit than most other institutions," he said. "But you can't judge what every student is doing in his room.... We can have students that overindulge in alcohol to the point where they're placed in the hospital. We can have students cheat."

How EthicsPoint Works
EthicsPoint provides users with a secure means for reporting not just incidents of academic misconduct or problems with substance abuse, but also theft, conflict of interest, discrimination, harassment, labor violations, data breaches, financial fraud, and other forms of malfeasance.

Once an event is reported, the program notifies the appropriate individuals in the organization to do follow-up work by logging into the service. At no point do they find out who reported the incident. If followup is required, the system allows recipients to post additional questions to the reporter or to request a real-time chat, while still ensuring the reporter's anonymity. The reporter receives a report key, enabling him or her to log in to check for follow-up. If the reporter chooses not to respond to request for additional information, the school must decide how to proceed without further input from that person.

At Thunderbird, when a member of the staff or faculty files a report, the notification is sent to the president, the in-house counsel, and the chairman of the audit committee, as well as Crystal Shanahan, director of administrative services and also the school's compliance officer. Shanahan reviews the report and decides whether to send it to another member of the human resources department, where she works. It's also her responsibility, she said, to "monitor the progress, and make sure that action is being taken in a timely manner, that responses are being provided to the reporter, and that any follow up is handled."

When the report involves a student rather than a staff member, the notification is sent to Scott in his capacity as the registrar rather than to in-house counsel or the audit committee.

6 Incidents in 3 Years
The school spends about $2,500 a year for the EthicsPoint service. At the time Scott and Shanahan were interviewed for this article, it had been used in only six incidents--twice by students and four times by staff members.

Both student reports involved postings to social networking sites, said Scott, "places the school isn't going to be checking, which gave us alerts that somebody was having problems."

In spite of its scant usage, Michael Rasmusson, president of Corporate Integrity, a firm that advises on compliance issues, said he considers products such as EthicsPoint a required investment.

"These platforms are pretty much a standard," he said. "In fact, if you don't have them in place, it could add significant liability and exposure." He pointed to the regulations of the United States Sentencing Commission, an agency in the judicial branch of government, specifying what makes for an "effective compliance and ethics program." Among the criteria, "a system, which may include mechanisms that allow for anonymity or confidentiality, whereby the organization's employees and agents may report or seek guidance regarding potential or actual criminal conduct without fear of retaliation." According to Rasmusson, courts will scale back or accelerate fines or other punishments in situations where those mechanisms don't exist.

The fact that the mechanism is delivered by an outside service is also important to its overall effectiveness as a risk management tool, Rasmusson added. "That shows that the organization isn't trying to control or mess with how things are being reported," he explained. "Most organizations want to go to an external provider so they have that independent objectivity."

Fear of litigation wasn't necessarily the main driver for adopting the program at Thunderbird, said Shanahan. It was the introduction of The Sarbanes-Oxley Act of 2002 that compelled the school's Board of Trustees to consider it. Although Thunderbird isn't a public company, the Board decided that because the school's focus was business, it should run operations in a business-like manner, including implementation of internal controls such as EthicsPoint.

The Importance of Anonymity
Prior to opening EthicsPoint up to students, Thunderbird relied on an e-mail address, [email protected], to allow students to report incidents to the Honor Council. But, said Scott, they were reluctant to do that. "Students felt they could be tracked back. They felt they could be identified. We were looking for another way to be able to allow students to make a report and follow up with it."

That anonymity is important, explained Rasmusson. "These are sensitive records. You want to make sure that access to and security of any information collected is there, as well as that there's complete anonymity--that people can report things without fear of reprisal."

When Scott demonstrated the system to the Honor Council before it was adopted for student usage, he recalled, "They kept asking, 'Is it anonymous?' The fact that it was is very important to the student body here. There are a lot of cultures where you don't report [problems to the authorities], which makes it difficult to get information."

Beyond security, another feature that may be essential to a college or university, according to Rasmussen, is a multi-lingual reporting capability. "If you have a significant number of students coming from other countries that speak different languages, you might want to make sure you have a hotline system that can communicate in different languages. If somebody is emotional or upset, you want to let them communicate in a language they're comfortable in."

The international flavor of the student population is always a consideration at Thunderbird. Scott said he'd wanted to call the EthicsPoint service "the Buddy System," but the Honor Council suggested that the student body wouldn't understand what a buddy system was. "So that's why we call it the Student Welfare System."

'Hotline' Options
Rasmusson considers EthicsPoint one of the better offerings in the category of hotline services since it includes functionality to help manage the investigation, automatically keep track of who needs to be involved, and maintain an audit of follow-up activity. But he cites several competitors in the sector, including Global Compliance, The Network, Allegience's SilentWhistle, and ELR Electronic Report Line from The Human Equation.

Thunderbird evaluated several of those services. "EthicsPoint just suited us the best," said Shanahan. "We've been really happy with them. They provide really good customer service. They've tweaked the system when we've needed it." That tweaking included adding Thunderbird branding to the site.

Publicizing the existence of the reporting system is an ongoing process. When it was first introduced to students, the Honor Council and the student government talked it up, said Scott. Information was also published in a student paper and in update messages e-mailed from the vice president of full-time programs. Also, a button exists on the intranet that takes users directly to the service. For faculty and staff, the service is also included in their orientation process.

"It's one tool of many that we use to get information on what's happening with students," said Scott. "But I think it's one of the more important one. Even though we've only had two reports that dealt with student welfare, it's most likely the tool where I'm going to get something that's really actionable to work on."

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