Ethics & Compliance

At FGCU, We're Committed to Ethical Conduct and Compliance on All Levels.

If you have questions or concerns about ethics or compliance, we're here to help. We provide training, monitoring and investigative activities to prevent, detect and resolve issues of non-compliance.

Report Concerns Anonymously Through Our Hotline

FGCU’s Hotline is an anonymous reporting mechanism that facilitates reporting of alleged illegal, unethical, or improper conduct. The Hotline is available 24 hours a day, 365 days a year, and is administered by an independent, third-party provider.  The Hotline provides a web-based reporting capability as well as a toll-free telephone-based service.  

SUBMIT REPORT

  • What is the FGCU Hotline?

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  • Who can submit a concern to the Hotline?

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  • When can I submit a concern to the Hotline?

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  • What kinds of concerns should I report?

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  • I’m not sure if what I observed is a violation of university policy or rises to the level of misconduct, but it doesn’t look right to me. What should I do?

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  • Why did FGCU implement the Hotline?

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  • Why can’t I just report observed violations to my supervisor or manager?

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  • Do the FGCU Board of Trustees, President and Cabinet encourage reporting?

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  • I am aware of misconduct on campus, but it does not affect me. Why should I report it?

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  • I am concerned that the information I provide will ultimately reveal my identity. How can you assure me that will not happen?

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  • Isn’t this system just an example of someone watching over me?

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  • What if I remember something important about the incident after I file a report? What if the University has further questions for me?

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  • What if I want to be identified with my report?

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  • Where do reports go? Who can access them?

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  • What are my responsibilities in bringing forward a concern?

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  • If I submit credible evidence of wrongdoing that results in a formal review, how long will the review take?

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What if I just want some advice and assistance from the University. Do I have to use the EthicsPoint Hotline?

Fortunately, FGCU has in place some excellent resources for its faculty, staff, and students. In addition to the EthicsPoint Hotline system to bring forward good-faith concerns of wrongdoing, you can always discuss a matter with:

  • Your supervisor or manager;
  • Precious Gunter, Chief Ethics and Compliance Officer and Title IX Coordinator, for harassment, discrimination and sexual misconduct allegations or for violations of University policy or regulation at (239) 745-4366 or pgunter@fgcu.edu;
  • Daniel Hoover, University Ombuds, for informal, impartial and non-adversarial alternatives concerning conflict management at (239) 590-1022 or dhoover@fgcu.edu; 
  • Daniel Teliski, Assistant Athletics Director for Compliance, for NCAA compliance concerns at dteliski@fgcu.edu; 
  • Rosemary Higgins, Associate Vice President, Research and Sponsored Programs, for research misconduct concerns, at (239) 590-7021 or rhiggins@fgu.edu;
  • Suzy Jones, Dean of Students for Care and Conduct, for academic integrity concerns, at (239) 590-7900 or sujones@fgcu.edu; 
  • Bill Foster, Director of Internal Audit, for fraud, waste, and abuse allegations at (239) 590-1709 or wfoster@fgcu.edu;
  • Rhonda Holtzclaw, Director of Environmental Health and Safety, for environmental health and safety concerns at (239) 590-1037 or rholtzcl@fgcu.edu;

Ethics & Compliance Guiding Documents

For more information on ethics & compliance at FGCU, please visit our guiding documents.

Conflict of Interest Reporting (Navex)

Annually all employees submit online disclosures about any (potential) Conflicts of Interest they may have. These forms must also be submitted if circumstances change and a different Conflict of Interest arises. The OIEC coordinates the annual disclosure process in partnership with Compliance Partners who directly manage Conflicts of Interest in their functional areas. 

Navex Hub to access disclosure link

Conflict of Interest Matrix 

Quick Reference Guide for Employees

Quick Reference Guide for Managers

  • Who submits disclosures through Navex? How do OPS employees submit disclosures?

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  • What do I need to disclose?

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  • My employee disclosed a potential conflict of interest. What do I do as a manager/supervisor?

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  • I have a question about a specific Conflict of Interest topic. Who should I contact?

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  • Where can I find the disclosure form? When I do need to submit the form?

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External Resources

Ethics & Compliance at FGCU is guided by external standards from a state and federal level. 

Prohibited Expenditures – BOG 9.016

Florida Board of Governors Regulation 9.016

Pursuant to the Board of Governors’ Regulation 9.016 Prohibited Expenditures, adopted in January 2024, and the 2023 amendments to section 1004.06, Florida Statutes, the University (and its Direct Support Organizations) may not expend any state or federal funds to promote, support, or maintain any program or campus activity that:

  • advocates for diversity, equity, and inclusion;
  • engages in political or social activism; or
  • violates section 1000.05, Florida Statutes,

unless an applicable exemption applies. Each bolded term is relevant in applying this regulation.

The following provides a framework for analyzing whether an expenditure in support of a program or campus activity is covered by the Regulation.

  • Step One: Does the program or campus activity expend state or federal funds?

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  • Step Two: Is it a program or campus activity?

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  • Step Three: Does the program or campus activity do one or more of the things listed in the Regulation?

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  • Step Four: Is there an applicable exemption for the expenditure on the program or activity?

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