USP Whistleblower and Non-Retaliation Policy

Reporting Responsibility

Each employee, officer, trustee, and volunteer of USP has an obligation to report all suspected questionable or improper accounting or auditing matters, violations of law, fraud, or other failures to comply with USP's Policies or related rules or procedures (Concerns). Such Concerns may be brought to the attention of an employee's supervisor or reported to USP's Chief Legal Officer or the Chairperson of the Audit Committee.

Anonymous Reporting

Concerns may be reported anonymously by using the Whistleblower Reporting Form or USP Hotline. USP will not monitor or record access to the Form or Hotline. All reports of Concerns will be shared with the Chairperson of the Audit Committee. If deemed appropriate by the Chief Legal Officer, a Concern may be shared with the Executive Vice President – Chief Executive Officer; provided, that a Concern shall not be shared with any executive who is the subject of, or who supervises a department that is the subject of, such Concern.

Investigation of Concerns

A Concern may be investigated internally or externally, as deemed appropriate by the Chief Legal Officer and the Chairperson of the Audit Committee. Reports of Concerns, and information gathered during an investigation thereof, shall be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Any person interviewed or participating in the investigation will be advised that the information disclosed or uncovered during the investigation, as well as the fact of investigation itself, are considered confidential. No person shall investigate a matter if he or she is the subject of a Concern, or if management deems that a potential conflict of interest exists. Outside legal counsel, accountants, investigators, or other resources may be retained if necessary to conduct a full and complete investigation of the allegation. All investigations shall be handled expeditiously, and appropriate corrective action shall be recommended and implemented. The results of all investigations, along with any recommended corrective action, shall be reported to the Audit Committee.

No Retaliation

This policy is intended to encourage and enable employees, officers, trustees, and other volunteers to raise Concerns within USP for investigation and appropriate action. With this goal in mind, no employee, trustee, or volunteer who, in good faith, reports a Concern shall be subject to retaliation or, in the case of an employee, adverse employment consequences. This policy also prohibits retaliation against any individual who assists or participates in any investigation or proceeding relating to any alleged violation of any law, regulation, policy, or other rule or procedure. Moreover, anyone who retaliates against an employee or volunteer who has reported a Concern in good faith is subject to appropriate disciplinary measures up to and including termination.

Acting in Good Faith

Anyone reporting a Concern must act in good faith and have reasonable grounds for believing the information disclosed indicates a basis for a Concern. The act of making allegations maliciously, recklessly, or with the knowledge that the allegations are false, will be viewed as a serious offense and may result in appropriate disciplinary measures.

How to Report

Employees may report Concerns to their supervisors. In addition, anyone may report a Concern in one of the following ways:

1. Contact the Chief Legal Officer in person or by telephone at (301) 816-8296, or via e-mail at
2. Complete the Whistleblower Reporting Form  (28KB) and mail to the address on the form
3. Leave a message at the USP Hotline (+1-301-881-0666, ext. 8000)
4. Contact the Chairperson of the Audit Committee, Dr. Larry Braden, at (770) 974-5234 or .