No: ELO:2014:01
Issuing Authority: =
Rowan President
Responsible Authority: =
Executive Vice President for Administration & Strategic Adva=
ncement
Adopted: 08/21/2014=
Reviewed: 11/12/2018
Last=
Revision: 01/08/2021<=
/h2>
I. PURPOSE
Rowan University is committed to ethical conduct in all of its operation=
s. At the very minimum, all employees, contractors, representatives or agen=
ts are responsible to ensure that their activities on behalf of the Univers=
ity, and those of their colleagues, comply with all applicable federal and =
state laws and Rowan University policies. To that end, all employees have a=
responsibility and an affirmative duty to report actual or suspected wrong=
ful conduct, and the University has a responsibility to make sure that they=
can do so without fear of retaliation or reprisal. All Such reports that a=
re filed in good faith shall be accepted, kept confidential to the extent p=
ossible in conformance with applicable laws, regulations and University pol=
icies and procedures, evaluated fairly and addressed promptly and appropria=
tely.
II. ACCOUNTABILITY
This policy applies to and should be read by all employees, students emp=
loyed by the university, contractors, representatives or agents of the scho=
ols, departments and units that are a part of Rowan University as to their =
duty to report suspected wrongdoing, the methods they may use to meet their=
reporting requirements and the protections in place for individuals who pr=
ovide reports of suspected wrongdoing in good faith.
This policy can be found on the University website as follows: <=
/span>www.rowan.ed=
u/compliance /reportin=
g .
III. APPLICABILITY
It is the policy of Rowan University that employees, students employed b=
y the university, contractors, representatives or agents have a duty to rep=
ort suspected wrongful conduct and they should be able to meet this duty wi=
thout the fear of retaliation or reprisal. This policy gives everyone the o=
pportunity to help Rowan achieve its mission.
IV. REFERENCES
- The Rowan University Voluntary Compliance Plan effective September=
26, 2014.
- The Medicare and Medicaid Patient Protection Act of 1987, as amended,
42 U.S.C. =C2=A71320a- 7b (the "Anti-kickb=
ack Statute"),
- Stark Law, 42 CFR =C2=A7=C2=A7 411.350 =
=E2=80=93 411.389.
- New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., ., also known a=
s the "Whistleblower Act").
- Sarbanes-Oxley not only prohibits retaliating against whistleblowers (S=
OX section 806), it also affirmatively requires companies to set up hotline=
s or other "procedures" for the "confidential, anonymous submission of empl=
oyee complaints and concerns" about audit/accounting fraud (SOX section 301=
).
V. POLICY
All employees have a responsibility and an affirmative duty to report ac=
tual or suspected wrongful conduct, and the University has a responsibility=
to make sure that they can do so without fear of retaliation or reprisal.<=
/p>
Reporting Policy Violations & Crime
Employees, students employed by the university and even contractors =
occasionally violate university policy or even commit crimes. Unfortunately=
, there are times when these behaviors go unreported because people fear re=
prisal or retribution from those who are committing the acts.
Rowan University prohibits retaliation, harassment, intimidation or =
discrimination against any individual who makes a good faith report of susp=
ected wrongdoing. If something seems wrong, it may be, so employees are enc=
ouraged to report it.
Reporting compliance and ethics concerns
University Ethics Liaiso=
n Officer (ELO), established under Executive Order 24 (Christie). Th=
e University's ELO is Ray Braeunig who is located on the Stratford Campus i=
n the University Education Center (UEC-1108). He can be reached at 856-566-=
6136.
University Chief Audit, =
Compliance & Privacy Officer, Ray Braeunig. As Compliance =
Officer, he is obligated by law to report any violations of any Federal Hea=
lth Care program requirements or of Rowan's own Policies & Procedures t=
o the Office of Inspector General (OIG). While his Compliance duties relate=
primarily to Federal Health Care program requirements, his duties as Priva=
cy Officer extend across all campuses.
University Equity and Di=
versity Office is located at the Glassboro Ca=
mpus in Linden Hall, 856-256-5831. The Office of Equity and Diversity=
oversees compliance with policies that include but are not limited to: The=
NJ Policy Prohibiting Discrimination in the Workplace, Americans with Disa=
bilities Act, Title IX Compliance, Rowan University Workplace Violence Poli=
cy, and EEO Compliant Search Practices..
As always, report immediate threats or danger by calling 911. Other =
University contacts include:
The obligations and authority of these offices overlap in some measu=
re, but their jurisdictions and authority are different. Calls to them are =
confidential, and they will direct you to the right area based on the issue=
or registered concern.
The university also maintains a confidential hotline. It is the Rowan University Integrity Hot=
line; available 24 hours a day/7days a week, via a=
toll free phone number, 1 855-431-9967, and via a website: http://rowan.edu/integrityli=
ne.
The schools, departments and units that are a part of Rowan Universi=
ty have established, and shall continue to maintain, effective and confiden=
tial means for individuals to report allegations or concerns that include a=
ctual or suspected violations of law, violations of Rowan University polici=
es or procedures, or any other type of wrongful conduct. Individuals will b=
e permitted to make such reports anonymously if they so desire, and their a=
nonymity will be protected to the extent possible and as permitted by law.<=
/p>
To make a report, individuals may contact their direct manager or ot=
her members of their management team. In addition, individuals may call the=
units Compliance Office, General Counsel; Ethics Liaison Officer; or they =
may call the Rowan University Integrity Line.
Integrity hotline: 855-431-9967
New in 2014, Rowan has created a phone hotline for those who want to=
report issues confidentially (to the extent possible) to an outside agency=
. The hotline, (855) 431-9967, is managed by Global Compliance, an independ=
ent organization that provides a secure and confidential means to file a re=
port 24 hours a day, seven days a week. The system accommodates callers in =
150 languages as well as callers with special needs.
Global Compliance logs each and every report. Whether you use the In=
tegrity Hotline Phone number or website the Rowan University-Integrity Hotl=
ine allows you to report issues and concerns you may have (regarding but no=
t limited to), unethical behavior, inappropriate conduct, bullying, harassm=
ent, and any other violation to Rowan University policies. This reporting p=
rocess is secure and confidential. The organization prioritizes the speed w=
ith which reports must be addressed as follows:
Priority A =E2=80=93 =
Immediate
Priority B =E2=80=93 Moderate
Priority C =E2=80=93 Standard
A committee of two University employees reviews each and every repor=
t. Should they believe the report involves factors that require greater per=
spective and independence they have access to outside investigators.
Visit www.rowan.edu/compliance to learn mor=
e about Rowan's policy on Reporting Compliance and Ethics Concerns, the pro=
tection afforded to employees who report violations and rights of individua=
ls accused of wrongdoing.
Protection from reprisal or retaliation
Rowan University policy prohibits retaliation, harassment, intimidat=
ion or discrimination against individuals who make good faith reports of su=
spected wrongdoing. Any employee found to have retaliated against anyone wh=
o has made a good faith report shall be subject to appropriate disciplinary=
action up to and including termination of employment. Good faith reports t=
hat are not substantiated are protected under this policy.
Complaints made in bad faith using falsified information is contrary=
to the intent and spirit of this policy, and may subject the reporter to d=
isciplinary action up to and including termination.
To make reports of immediate threats or danger, call 911. The Rowan =
University Alert Line should not be used for emergencies. There are other r=
eporting methods for concerns which are summarized in Attachment 2.
Retaliation & Whistleblower Protection
Reporting and Investigating Retaliation Allegations:
Reporting: Anyone who has provided information who believes he or sh=
e is the subject of retaliation should report the facts supporting the alle=
gations of retaliation to the Chief Compliance Officer; Assistant Vice Pres=
ident Equity and Diversity; General Counsel, Ethics Liaison Officer (ELO) o=
r the Alert Line.
All investigations of alleged retaliation will be conducted as sensi=
tively and expeditiously as possible. Due consideration will be given to ex=
isting grievance procedures under applicable collective bargaining agreemen=
ts.
Should an investigation lead the appropriate Rowan University author=
ity to conclude that retaliation has been substantiated; the individual(s) =
responsible for committing the retaliation, in addition to any civil or cri=
minal proceedings, shall be subject to disciplinary action up to and includ=
ing termination.
In accordance with New Jersey's Conscientious Employee Protection Ac=
t (N.J.S.A. 34.19-1 et seq., also known as the "Whistleblower Act"), Rowan =
University shall take no retaliatory action against an employee as identifi=
ed in Attachment 1.
The Conscientious Employee Protection Act Annual Notice is Attachmen=
t 1.
Sanctions
Failure to comply with this policy may result in sanctions up to, an=
d including, termination of employment or termination of a contractor's agr=
eement.
Communications
As Rowan University grows it is important to ha=
ve process in place to ensure concerns are addressed in a timely and a=
efficient basis. Effective communication is necessary for a University to =
swiftly communicate information to personal that are a part of Rowan Univer=
sity to report Non-compliant activities. The document below provides a mech=
anism for anonymous and confidential reporting without any form of retaliat=
ion. It also provides a wide array of direction for all Rowan personal to a=
ddress concerns. Please read and keep this information available to you.
Notices: Posters will be placed in each Human Resource site for =
each Rowan University unit/school. See below Attachment 1 =E2=80=93 Annual =
Notice.
Email: An email will be sent in the second week of the=
fall, spring and summer terms of each year to all faculty, staff, students=
employed by the university and Trustees.
VI. ATTACHMENTS
- Attachment 1 - Annual Notice
- Attachment 2 - Type of Issue
- Attachment 3 - Integrity Hotline Investigation Process
ATTACHMENT 1
=
Annual Notice
CONSCIENTIOUS EMPLOYEE PROTECTION ACT
"WHISTLEBLOWER ACT"
Employer retaliatory action; protected employee actions; employee respon=
sibilities
- New Jersey law prohibits an employer from taking any retaliatory action=
against an employee because the employee does any of the following:
- is in violation of a law, or a rule or regulation issued under the law =
or, if the employee is a licensed or certified health care professional, co=
nstitutes improper quality of patient care;
- is fraudulent or criminal; or
- is incompatible with a clear mandate of public policy concerning the pu=
blic health, safety or welfare or protection of the environment. N.J.S.A. 3=
4:19-3.
- Discloses, or threatens to disclose, to a supervisor or to a public bod=
y an activity, policy or practice of the employer or another employer, with=
whom there is a business relationship, that the employee reasonably believ=
es is in violation of a law, or a rule or regulation issued under the law, =
or, in the case of an employee who is a licensed or certified health care p=
rofessional, reasonably believes constitutes improper quality of patient ca=
re;
- Provides information to, or testifies before, any public body conductin=
g an investigation, hearing or inquiry into any violation of law, or a rule=
or regulation issued under the law by the employer or another employer, wi=
th whom there is a business relationship, or, in the case of an employee wh=
o is a licensed or certified health care professional, provides information=
to, or testifies before, any public body conducting an investigation, hear=
ing or inquiry into quality of patient care; or
- Provides information involving deception of or misrepresentation to, an=
y shareholder, investor, client, patient, customer, employee, former employ=
ee, retiree or pensioner of the employer or any governmental entity.
- Provides information regarding any perceived criminal or fraudulent act=
ivity, policy or practice of deception or misrepresentation which the emplo=
yee reasonably believes may defraud any shareholder, investor, client, pati=
ent, customer, employee, former employee, retiree or pensioner of the emplo=
yer or any governmental entity.
- Objects to, or refuses to participate in, any activity, policy or pract=
ice which the employee reasonably believes:
- The protection against retaliation, when a disclosure is made to a publ=
ic body, does not apply unless the employee has brought the activity, polic=
y or practice to the attention of a supervisor of the employee by written n=
otice and given the employer a reasonable opportunity to correct the activi=
ty, policy or practice. However, disclosure is not required where the emplo=
yee reasonably believes that the activity, policy or practice is known to o=
ne or more supervisors of the employer or where the employee fears physical=
harm as a result of the disclosure, provided that the situation is emergen=
cy in nature.
CONTACT INFORMATI=
ON
The following contact persons at Rowan University have been designated to a=
nswer your questions or provide information regarding your rights and respo=
nsibilities under the Whistleblower Act (N.J.S.A. 34:19-4):
*Name: Ray Braeunig
Address: Stratford Campus - University Educational Center (UEC)
Telephone Number: (856) 566-6136
Or
*Name: Rowan University Integrity Line
Telephone Number: 1-855-431-9967
Website Access: http://rowan.edu/integrityline<=
span style=3D"text-decoration: underline;">.
This notice must be conspicuously displaye=
d.
Once each year, employers must distribute notice of this law to their emplo=
yees.
If you need this document in a language other than English
or Spanish, please call (609) 292-7832.
AD-270 (3/06)
La Ley de protecci=C3=B3n al
empleado con=
sciente
"Ley de protecci=C3=B3n del denunciante"
Acciones de represalia del empleador; protecci=C3=B3n de las acciones de=
l empleado
- La ley de New Jersey proh=C3=ADbe que los empleadores tomen medidas de =
represalia contra todo empleado que haga lo siguiente:
- Divulgue o amenace con divulgar, ya sea a un supervisor o a una agencia=
p=C3=BAblica toda actividad, directriz o norma del empleador o de cualquie=
r otro empleador con el que exista una relaci=C3=B3n de negocios y que el e=
mpleado tiene motivos fundados para pensar que violan alguna ley, o en el c=
aso de un trabajador licenciado o certificado de la salud y que tiene motiv=
os fundados para pensar que se trata de una manera inadecuada de atenci=C3=
=B3n al paciente;
- Facilite informaci=C3=B3n o preste testimonio ante cualquier agencia p=
=C3=BAblica que conduzca una investigaci=C3=B3n, audiencia o indagaci=C3=B3=
n sobre la violaci=C3=B3n de alguna ley, regla o reglamento que el empleado=
r o alg=C3=BAn otro empleador con el que exista una relaci=C3=B3n de negoci=
os; o en el caso de un trabajador licenciado o certificado de la salud que =
facilite informaci=C3=B3n o preste testimonio ante cualquier agencia p=C3=
=BAblica que conduzca una investigaci=C3=B3n, audiencia o indagaci=C3=B3n s=
obre la calidad de la atenci=C3=B3n al paciente; o
- Ofrece informaci=C3=B3n concerniente al enga=C3=B1o o la tergiversaci=
=C3=B3n con accionistas, inversionistas, usuarios, pacientes, clientes, emp=
leados, ex empleados, retirados o pensionados del empleador o de cualquier =
agencia gubernamental.
- Ofrece informaci=C3=B3n '63on respecto a toda actividad que se pueda pe=
rcibir como delictiva o fraudulenta, toda directiva o pr=C3=A1ctica enga=C3=
=B1osa o de tergiversaci=C3=B3n que el empleado tenga motivos fundados para=
pensar que pudieran estafar a accionistas, inversionistas, usuarios, pacie=
ntes, clientes, empleados, ex empleados, retirados o pensionados del emplea=
dor o de cualquier agencia gubernamental.
- Se opone o se niega a participar en alguna actividad, directriz o pr=C3=
=A1ctica que el empleado tiene motives fundados para pensar que:
- viola alguna ley, o regla o reglamento que dicta la ley o en el caso de=
un empleado licenciado o certificado de la salud que tiene motivos fundado=
s para pensar que se trata de la atenci=C3=B3n inadecuada al paciente;
- es fraudulenta o delictiva; o
- es incompatible con alg=C3=BAn mandato establecido por las directrices =
p=C3=BAblicas relacionadas con la salud p=C3=BAblica, la seguridad o el bie=
nestar o la protecci=C3=B3n del medio ambiente. Art=C3=ADculo 34:19-3 de la=
s Leyes comentadas de New Jersey de protecci=C3=B3n del empleado consciente=
(N.J.S.A., por sus siglas en ingl=C3=A9s)
- No se puede acoger a la protecci=C3=B3n contra la represalia, cuando se=
hace una divulgaci=C3=B3n a un organismo p=C3=BAblico, a no ser que el emp=
leado le informe al empleador de tal actividad, pol=C3=ADtica o norma a tra=
v=C3=A9s de un aviso por escrito y le haya dado al empleador una oportunida=
d razonable para corregir tal actividad, pol=C3=ADtica o norma. Sin embargo=
, no es necesaria la divulgaci=C3=B3n en los casos en que el empleado tenga=
indicios razonables para creer que un supervisor o m=C3=A1s de un supervis=
or del empleador tienen conocimiento de tal actividad, pol=C3=ADtica o norm=
a o en los casos en los que el empleado teme que tal divulgaci=C3=B3n pueda=
traer como consecuencia da=C3=B1os f=C3=ADsicos a su persona siempre y cua=
ndo la naturaleza de la situaci=C3=B3n sea la de una situaci=C3=B3n de emer=
gencia.
Informaci=C3=B3n del Co=
ntacto
La persona siguiente para ha sido designada a contestar sus preguntas
o, proporcionar informaci=C3=B3n adicional relacionada con sus derechos y
responsabilidades seg=C3=BAn lo indica esta ley (N.J.S.A. 34:19-4):
- Nombre: Ray Braeunig
Direcci=C3=B3n: Stratford Campus - University Educational Center (UEC) =
;
N=C3=BAmero de tel=C3=A9fono: (856) 566-6136
- Nombre: Rowan University Integrity Line
Direcci=C3=B3n:
N=C3=BAmero de tel=C3=A9fono: (855) 431-9967
Website: http:/=
/rowan.edu/integrityline
Este aviso se debe exponer a l=
a vista de todos.
Una vez por a=C3=B1o, los empleadores deben de distribuir un aviso de esta =
ley a sus empleados. Si necesita este documento en alg=C3=BAn otro idioma q=
ue no sea ingl=C3=A9s o espa=C3=B1ol, s=C3=ADrvase llamar al (609) 292-7832=
. Posiblemente, una carga nominal puede ser cobrada.
ATTACHMENT 2
TYPE of ISSUE
Where to go for support/direction and how to=
report an issue
Abuse/neglect of minors
- New Jersey law (NJSA 9:6-8.10) requires all persons who have reasonable=
cause to believe that a minor has been subject to abuse or neglect to repo=
rt it to the New Jersey Division of Child Protection and Permanency, former=
ly the Division of Youth and Family Services (DYFS) at 1-877-NJABUSE (1-877=
-652- 2873).
- Anyone who suspects that a minor has been subject to abuse or neglect m=
ust immediately notify the Rowan University Police Department (RUPD) at 856=
-757-7777.
- Website Page, Contacts=
- Protection of Minor=
s Policy
Accident/Injury
- In an Emergency, call 911
- Job-rel=
ated injury reporting
- Injury Re=
porting Form for Student or the Public
Alcohol and Drug Use; Alcoho=
l on Campus
- The resources available to employees and supervisors relating to alcoho=
l and drug use/abuse may be accessed in Rowan University Policy Alcohol and Other D=
rugs Policy
- Employees are encouraged to seek assistance through the Faculty and Sta=
ff Assistance Program if they believe they may have an alcohol or other dru=
g abuse problem- Rowan University Policy Alcohol and Other Drugs Policy
Animal Research Violations o=
f NIH, USDA, AAALAC Regulations
http://www.rowan.edu/open/provost/research
Animal Welfare Regulations
Rowan University Institutional A=
nimal Care & Use Committee
- The Office of Research and Sponsored P=
rograms provides information relating to the use of a=
nimal in research.
Conflict of Interest violati=
on of DHHS, FDA, NSF or other Federal Agency Regulations
- Contact the Office of the Vice President of Research and Economic Devel=
opment.
http://www.rowan.edu/open/provo=
st/research/Integrity_and_compliance/Integrity_and_compliance.cfm
http://www.rowan.edu/=
som/research/admin.html
Critical information system =
being hacked or compromised (Oracle PeopleSoft, Ba=
nner, e-mail)
- Rowan Information Resource Technology=
- Disabili=
ty: Americans with Disabilities Act (faculty-related)
- Academic Labor Relations
Disability: Americans with D=
isabilities Act (staff-related)
- Office o=
f Employee Equity and Labor Relations
Disability: Americans with D=
isabilities Act (student-related)
- Rowan Un=
iversity Academic Success Center
- RowanSOM Office of Student Affairs
Discrimination
- Policy Prohib=
iting Discrimination and Harassment
- Office of Employee Equity and La=
bor Relations
- Rowan University Office of Community Standards & Commuter S=
ervices
- RowanSOM=
Student Handbook
- Rowan Student Handbook
Export Cont=
rols (Research)
- Rowan University=
Office of the Vice President of Research
Fair Labor Standards Act and=
Overtime Provisions
- UHR Policies =
and Resources
- Office of Labor Re=
lations - contact, Interim Assistant Vice President f=
or Employee Equity and Labor Relations, 856-256-4320
- UHR Compensat=
ion
Fraud (Financial)
- Internal Audit Department
Harassment
- Policy Prohibiting Discrimination an=
d Harassment
- Office of Employee Equity and La=
bor Relations
- Harassment: A=
Guide for Faculty
- Harassment: A=
Guide for Staff
- Harassment: A Guide for Students
Student Sexual Misconduct an=
d Harassment Policy
http://www.rowan.edu/equity/TITLEIX =
;
- Code of Student =
Conduct
- Office o=
f Student Conduct
Employee Sexual Misconduct a=
nd Harassment Policy
- Policy Prohibi=
ting Discrimination in the Workplace and Educational Environment=
Healthcare Compliance=
- RowanSOM Office of Co=
mpliance and Corporate Integrity (856) 566-6136.
Human Subject Research Viola=
tions of DHHS/OHRP, FDA and other Federal Regulations pertaining to human s=
ubject research
- Office of the V=
ice President of Research and Economic Development IRB and Compliance Admin=
istrator
Improper accounting and cost=
ing on sponsored projects
- Rowan University Office of Sponsored Programs=
li>
- RowanSOM Research A=
dministration
Improper document of or bill=
ing for healthcare goods or services
- RowanSOM Office of Co=
mpliance and Corporate Integrity (856) 566-6136.
Laboratory Safety Violations=
- Rowan University Environment Health and Safety=
- RowanSOM Emergency M=
anagement =E2=80=93 contact Thomas Boyle at (856) 566=
-6289/ boyletp@rowan.=
edu or Department of Public Safety
Misconduct in Research inclu=
ding Falsification of Documents/Records
- University Policy for Dealing with Allegations of Misconduct in Research=
Open Public Meetings Act =E2=80=93
- Of=
fice of the Secretary of the University
Open Public Records Act =E2=
=80=93
- Of=
fice of the Secretary of the University
Public Safety/Emergency Mana=
gement
- Rowan University Public Safety<=
/a>
Radiation Safety Violation o=
f NRC or DCRA Regulations
- Laboratory Safety and Environmental Programs Radiation Safety Group
Records Management (e.g. document retention schedules, archiving documents)
- Records Retenti=
on Policy
Division of Administrat=
ion and Public Safety
Records: Loss of records; inabilit=
y to find records; improper release, disclosure or access to records=
Depending on the type of records, you may contact the following offi=
ces:
- RowanSOM Business or Financial Information: Office of the Secretary of =
the University, Custodian of Records
- Student Information: Office of Student Affairs Compliance=
a>
http://www.rowan.edu/e=
quity/titleix
htt=
p://www.rowan.edu/provost/registrar/
- Patient Information - RowanSOM Privacy Officer (856-566-6136) or ALERTL=
INE 1-855-431-9967, www.rowan.edu/compliance
- Non-public personal information of any individual, including credit car=
d information, social security numbers, driver's license numbers, etc. =E2=
=80=93 Compliance ALERTLINE-1-855-431-9967.
Director of Information Prot=
ection and Security or go to the Information Protection and Security websit=
e Research Compliance-
- Rowan University Information Resource Technology
- Rowan=
University Vice President of Research
Research: Sponsored Project =
Billing and Reporting
- Rowan University Office of Sponsored Program
RowanSOM Biomedical and Heal=
th Sciences Compliance Issues
- RowanSOM Office of Compliance a=
nd Corporate Integrity or call (856) 566-6136
Sexual Harassment
- Policy Prohibiting Discrimination an=
d Harassment
- Office of Employee Equity and La=
bor Relations
- Harassment: A Guide for Faculty<=
/a>
- Harassment: A Guide for Staff
- Harassment: A Guide for =
Students
Student Billings
- RowanSOM Office of Student Accounting, Billing and Cashiering
- http://www.rowan.edu/som/education/student_affairs/index.html
Student Loan Abuses=
p>
- Rowan Unive=
rsity Office of Financial Aid
- Rowa=
nSOM Office of Financial Aid
University Property: Loss or=
Theft
- If the loss or theft involves the loss of records or information, see
Loss of Records
Victim Assistance (and violence prevention)
- In an emergency, dial 911.
- Violence Prevention and Victim Assistance
Violation of OSHA, HFPA, BOC=
A, NRC, and FDA regulations
- Facilities=
-Rowan University Environment Health & Safety Department
- RowanSOM Emergency Management =E2=80=93 contact Thomas Boyle at (856) 566-6289/ boyletp@rowan.edu
- Department o=
f Public Safety
- Rowan University Radiation Safety Department
Violation of System Security=
- RowanSOM Information Resources & =
Technology
- Rowan Universit=
y Clinical Systems & Project Management
Violations of EPA regulations and Hazardous material releases=
- Emergency call 911
Worker's Compensation Laws=
span>
- New Jersey Department of Labor=
Workplace Violence-
-
- In an emergency, or if you experience or witness imminent or actual vio=
lence involving weapons or potential injuries, call 911.
- Any person who is the subject of, or witness to, a suspected violation =
of this policy should report the incident to his or her supervisor or, in l=
ieu thereof, to the appropriate Designated University Representative.
ATTACHMENT =
3
INTEGRITY HOTLINE INVESTIGATION PROCESS
NOTE: These investigative processes are general g=
uidelines. Depending on the policy being investigated, the investigation pr=
ocess may be different. The Integrity Hotline can be used by employee=
s and students as well as external visitors, and vendors. The followi=
ng investigation process guidelines do not apply to students. For informati=
on on student=E2=80=93on-student case please visit the Student Handbook=
.
- Hotline Reports
- A committee of Rowan University employees reviews each and every Hotlin=
e report. Once the report has been reviewed, the case is assigned to an inv=
estigator.
- The objective of the investigation is to determine the credibility of t=
he Reporter (employee who notified the Hotline) and reported allegation. If=
the Reporter has revealed his/her identity, the Investigator will contact =
the Reporter via telephone or email. The Investigator will ask the Reporter=
for available dates and times to schedule an interview to acquire more inf=
ormation about the reported allegation.
- It is the interviewed employee=E2=80=99s responsibility to notify his/h=
er superiors of the interview date and time. The Investigator will attempt =
to conduct the interview at a Rowan University location that will allow the=
employee to be relaxed and forthcoming.
- If the Reporter did not reveal their identity, the Investigator will at=
tempt to communicate with the anonymous Reporter, utilizing the Rowan Unive=
rsity Integrity Hotline website: www.rowan.edu/integrityline
- Communication with Reporter
- To effectively conduct an investigation, it is crucial for the anonymou=
s Reporter to maintain communication with the case Investigator by utilizin=
g the Communication with Reporter section of the website. The Reporter will=
need to know the case number and PIN for his/her case to continue communic=
ations with the Investigator. Without key information, it may be very=
difficult to effectively investigate the credibility of the allegation and=
may result in the allegation being classified as =E2=80=9Cunsubstantiated=
=E2=80=9D.
- It is very important to note, that any case may be re-opened, if add=
itional information is provided.
- At the inception of an investigation, when appropriate, the assigned In=
vestigator may notify the Vice President that oversees the area under inves=
tigation.
- Internal Investigation Interview(s)
- Internal Interview Introduction (information provided below is for g=
uidance purposes only and specific questions and areas of inquiry may vary =
based on the subject matter of the allegation and the specific policy invol=
ved)
- The Investigator will send a request to the employee to be interviewed =
labeled =E2=80=9CCONFIDENTIAL INTERVIEW=E2=80=9D. The employee will be requ=
ested to provide times they will be available for the interview. The employ=
ee will be requested to notify their department supervisor about the interv=
iew request. If the employee does not feel comfortable notifying their depa=
rtment supervisor, they may elect to notify the individual their supervisor=
reports to, or ask the Investigator to notify departmental management. The=
Investigator will attach the Investigation process to the CONFIDENTIAL INT=
ERVIEW invitation to provide the employee the opportunity to review. &=
nbsp;
- The Interviewed employee will be provided with the New Jersey State Pol=
icy Prohibiting Discrimination in the Workplace as well as Rowan University=
Workplace Violence Policy or any other policy related to the complaint, wh=
ich includes instructions regarding the Confidentiality, Prohibition agains=
t Retaliation of the information discussed during the interview and the emp=
loyee=E2=80=99s Weingarten Rights (for union employees). Employees wh=
o are members of the union may request union representation during the inte=
rview.
- The Interviewed employee will be asked to read and sign the confidentia=
lity form.
- The Investigator=E2=80=99s role will be explained to the employee.
- Interview ground rules will be explained, including, but not limited to=
answering the questions to the best of the interviewed employee=E2=80=99s =
ability. Please note that it is acceptable if the employee does not remembe=
r or does not know the answer to the question but inform the investigator o=
f that.
- The Investigator will determine the value of information reported by th=
ird parties, depending upon the allegation and how it relates to the case.&=
nbsp;
- Overview of the Allegation
- The allegations will be reviewed with the reporter and the Invest=
igator will ask for more in depth information regarding the allegatio=
n.
- The Investigator will request any evidence associated with the allegati=
on from any involved employee or department.
- The Reporter will be asked; what are your expectations or desired outco=
me to resolve this allegation.
- Interview Conclusion
- The Investigator will ask the employee if he/she has witnessed or has k=
nowledge of, any other unethical, fraudulent, discriminatory or criminal be=
haviors during his/her employment at Rowan University.
- The Investigator will review the Confidentiality statement and the No R=
etaliation Policy with the employee. The employee will be given the Investi=
gator=E2=80=99s contact information, in case the employee remembers additio=
nal information related to the case or if he/she feels that he or she is ex=
periencing adverse employment consequences based upon involvement in the in=
vestigation.
- The Investigator will interview employees who witnessed the incident or=
may have additional foundational knowledge related to the allegation. The =
allegation will not necessarily be disclosed during interviews performed to=
acquire foundational knowledge; only relevant information to that witness =
will be shared.
- The investigator will meet with the respondent/accused and review and d=
iscuss the allegations. A statement will be taken and incorporated into the=
investigative report.
- Investigation Analysis
-
- The Investigator will review all of the information provided in the int=
erviews and related evidence to determine if the allegation violates Rowan =
University Policy, New Jersey State and/or federal laws or regulations.
- If the facts of the case reveal a violation, then the allegation is con=
sidered substantiated.
- If the facts of the case reveal there has not been a violation, the all=
egation is considered unsubstantiated.
- If the facts of the case, do not allow the Investigator to determine th=
e credibility of the allegation, it is considered inconclusive.
- Investigation Conclusion
-
- Depending under what policy the investigation is taking place, the Inve=
stigator will discuss the Investigational conclusion(s) on allegations that=
have been substantiated only with the department management or director. T=
he Investigator may provide recommendations to the department management. T=
he Office of Compliance & Corporate Integrity will request a Corrective=
Action Plan (CAP) from the involved department and may audit the effective=
ness of the CAP, after it has been implemented. (Please note this =
does not always apply to Discrimination, Workplace Violence, or Title IX in=
vestigations.).
- The Investigator will communicate to the Reporter, thanking them for be=
ing forthcoming and that the investigation has been closed. &nbs=
p;
- The Investigator may also be required/requested to notify Rowan=E2=80=
=99s Office of General Counsel, Labor Relations Office, the Dean, President=
and/or Rowan University Board of Trustees Audit Committee, when appropriat=
e.
- If criminal behavior has been substantiated, the Investigator will noti=
fy the Office of General Counsel and/or law enforcement (when appropriate).=
- If the allegation has been determined to be inconclusive or unsubstanti=
ated, the case will be closed. If in the future, additional information is =
provided relating to the allegation, the case may be re-opened. Pleas=
e note that in cases of inconclusive or unsubstantiated determinations conc=
erns may be identified relating to process or procedure. In such case=
s, the investigator will alert appropriate university administrators of suc=
h concerns. Further, at the conclusion of the investigation, the Inve=
stigator will alert the department Vice President or other appropriate admi=
nistrator that the matter has been concluded.
- In order to preserve the integrity of the investigation, only the Execu=
tive Vice President and Rowan General Counsel=E2=80=99s Office will have ac=
cess to the full report of findings.
- Participation in an Internal Investigation
-
- Noted previously, employees are obligated to report concerns relating t=
o illegal and unethical conduct as well as potential policy violations.&nbs=
p; Such information is vital in ensuring that Rowan operates in a way that =
is compliant with applicable law and satisfies its mission.
- As such, Rowan University expects all employees to cooperate fully with=
internal investigations. If the employee refuses to cooperate =
with internal investigations, the employee may be subject to disciplinary a=
ctions, up to and including termination in accordance with applicable polic=
ies.
- Protection from Reprisal or Retaliation
- Rowan University prohibits retaliation, harassment, intimidation or dis=
crimination against individuals who make good faith reports of suspected wr=
ongdoing. Any employee found to have retaliated against anyone who ha=
s made a good faith report shall be subject to appropriate disciplinary act=
ion up to and including termination of employment. Good faith reports that =
are not substantiated are protected under this policy.
- Complaints made in bad faith using falsified information are contrary t=
o the intent and spirit of this policy, and may subject the reporter to dis=
ciplinary action up to and including termination.
- To make reports of immediate threats or danger, call 911. The Row=
an University Alert Line should not be used for emergencies.
- Retaliation & Whistleblower Protection
- Reporting and Investigating Retaliation Allegations:
- Reporting: Anyone who has provided information who believes he or she i=
s the subject of retaliation should report the facts supporting the allegat=
ions of retaliation to the Chief Compliance Officer; Assistant Vice Preside=
nt Equity and Diversity; General Counsel, Ethics Liaison Officers (ELO) or =
the Alert Line.
- All investigations of alleged retaliation will be conducted as sensitiv=
ely and expeditiously as possible. Due consideration will be given to exist=
ing grievance procedures under applicable collective bargaining agreements.=
- Should an investigation lead the appropriate Rowan University authority=
to conclude that retaliation has been substantiated; the individual(s) res=
ponsible for committing the retaliation, shall be subject to disciplinary a=
ction up to and including termination and may be subject to other civil or =
criminal proceedings under applicable law.
- Rowan University forbids retaliation in accordance with New Jersey=E2=
=80=99s Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., al=
so known as the =E2=80=9CWhistleblower Act=E2=80=9D). Rowan Universit=
y shall not engage in conduct prohibited by the act and employees who viola=
te the provisions shall be subject to disciplinary action.
- Corrective Action Plan (CAP)
- Depending upon the sensitivity of the substantiated allegation finding,=
the involved employees/department/unit may be requested to create a CAP (w=
hen appropriate) to resolve the allegation and provide an implementation da=
te. The Investigator will receive a copy of the CAP and implementation date=
.
- The Investigator may perform a follow up assessment of the effectivenes=
s of the CAP. If the CAP has been determined to be ineffective to resolve t=
he allegation, the Investigator follow up assessment may be discussed with =
the involved employees/departments/units to determine if there are addition=
al possible processes that will resolve the allegation.
- Frequently Asked Questions:
- How does the Anonymous Reporter, continue to communicate with the I=
nvestigator and still be anonymous?
- The Rowan Integrity Hotline website (Communication with the Reporter se=
ction) provides an area for the Reporter to communicate with the Investigat=
or anonymously. When the Reporter submits a case, they are provided a case =
number and PIN, which allows them access to this area. The Reporter=
will be required to use the case number and PIN to access the case in the =
future. It is very important to maintain this co=
mmunication, if the Reporter wants to see resolution to their allegation. I=
nvestigators will always have more questions.
- How does the Reporter know about the investigational findings?
- If the allegation has been substantiated, the Reporter should notice ch=
anges within their department and may be requested to assist to resolve the=
allegation.
- If the allegation has been unsubstantiated or inconclusive, the Reporte=
r may not notice any changes within their department.
- It is important to note that unsubstantiated and inconclusive cases =
may be closed, but have potential to be reopened, if additional information=
is provided. To maintain the confidentiality, Investigators consider these=
cases as having the potential to be re-opened.
- Will management be notified about the allegation or investigational=
finding?
- The Investigator will notify the departmental vice president or other a=
ppropriate administrator of a pending investigation unless doing so will im=
pact the integrity of the investigation. Further, to avoid being disr=
uptive to the department workflow, we welcome discussion with management ab=
out appropriate time to schedule an interview with the employee. To maintai=
n the confidentiality of the investigation, management will not be notified=
about investigational findings, unless they will need to be involved in th=
e Corrective Action Plan.
- Can the interviewed employee bring union or legal representatives t=
o the internal investigation interview?
- Yes. However, since the interviews are part of the administrative inter=
nal investigation and not considered a judicial proceeding, representatives=
may not participate in the interview questioning or answers. Union and leg=
al representatives will be required to sign a Rowan University Confidential=
ity form and will not be allowed to take notes of the interview.
- How long does an investigation take?
- The length of time for an investigation varies greatly and is dependent=
upon the nature of the allegation, the Investigator=E2=80=99s case load an=
d the amount of time needed to analyze evidence provided. However, Ro=
wan will attempt to resolve investigations in a timely manner.
- Do I have to be interviewed on my own time?
- Interviews will be scheduled during work time to encourage cooperation.=
However, employees are encouraged to consider departmental needs whe=
n scheduling time for interviews.
- Can we meet in a neutral location?
- Yes. The Investigator will meet with the employee in a neutral, r=
elaxing environment where the employee feels comfortable being forthcoming =
with appropriate information related to the allegation.
- What happens if I lose my case number and/or PIN?
- You should call the Office of Compliance and Corporate Integrity at 856=
-566-6299.
- Can the Reporter receive a copy of the case report?
- Rowan University Internal investigation reports are confidential and ar=
e only provided to the Executive Vice President and Office of General Couns=
el unless otherwise required by law.
- Should I report Human Resources or Labor Relations issues to Rowan =
University Hotline?
- Rowan University recommends that employees utilize their department =E2=
=80=9Cchain of command=E2=80=9D or the Human Resources office to report Hum=
an Resources issues. If the employee is a union employee, the employee may =
utilize his/her union contract process to report Labor Relation issues. Aft=
er the employee utilizes the established processes mentioned above and he/s=
he has not received a satisfactory response, he/she may decide to notify th=
e Rowan University Integrity Hotline.