ROWAN UNIVERSITY POLICY 

Title: Whistleblower Policy ("Reporting Compliance & Ethics Concerns")
Subject: Ethics
Policy No: ELO:2014:01
Issuing Authority:

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University President
Responsible Authority:

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Chief Audit, Compliance & Privacy Officer
Adopted: 08/21/2014
Last Reviewed:

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04/

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17/

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2026
Last Revision:

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04/

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17/

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2026
 

I. PURPOSE

Rowan University is committed to ethical conduct in all of its operations. At the very minimum, all employees, contractors, representatives or agents are responsible to ensure that their activities on behalf of the University, 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 wrongful 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 are filed in good faith shall be accepted, kept confidential to the extent possible in conformance with applicable laws, regulations and University policies and procedures, evaluated fairly and addressed promptly and appropriately.

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This policy applies to and should be read by all employees, students employed by the university, contractors, representatives or agents of the schools, 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 provide reports of suspected wrongdoing in good faith.
This policy can be found on the University website as follows: www.rowan.edu/compliance /reporting .

III. APPLICABILITY

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1. Reporting Policy Violations & Crime

   1. 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 reprisal or retribution from those who are committing the acts. 

   2. Rowan University prohibits retaliation, harassment, intimidation or discrimination against any individual who makes a good faith report of suspected wrongdoing. If something seems wrong, it may be, so employees are encouraged to report it.

2. Reporting compliance and ethics concerns

   1. University Ethics Liaison Officer (ELO), established under Executive Order 24 (Christie). The University's ELO is Ray Braeunig who is located on the Stratford Campus in the University Education Center (UEC-1108). He can be reached at 856-566-6136. 

   2. University Chief Audit, Compliance & Privacy Officer, Ray Braeunig.  As Compliance Officer, he is obligated by law to report any violations of any Federal Health Care program requirements or of Rowan's own Policies & Procedures to the Office of Inspector General (OIG). While his Compliance duties relate primarily to Federal Health Care program requirements, his duties as Privacy Officer extend across all campuses.

   3. Office of Employee Equity is located at the Glassboro Campus, 856-256-4251.  The Office of Employee Equity oversees compliance with policies that include but are not limited to: The NJ Policy Prohibiting Discrimination in the Workplace, Americans with Disabilities Act, Title IX Compliance, Rowan University Workplace Violence Policy, and EEO Compliant Search Practices..

   4. As always, report immediate threats or danger by calling 911. Other University contacts include: 

      1. The obligations and authority of these offices overlap in some measure, 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.

      2. The university also maintains a confidential hotline. It is the Rowan University Integrity Hotline; 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/integrityline.

      3. The schools, departments and units that are a part of Rowan University have established, and shall continue to maintain, effective and confidential means for individuals to report allegations or concerns that include actual or suspected violations of law, violations of Rowan University policies or procedures, or any other type of wrongful conduct. Individuals will be permitted to make such reports anonymously if they so desire, and their anonymity will be protected to the extent possible and as permitted by law.

      4. To make a report, individuals may contact their direct manager or other 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.  

3. Integrity hotline: 855-431-9967

   1. In 2014, Rowan 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 independent organization that provides a secure and confidential means to file a report 24 hours a day, seven days a week. The system accommodates callers in 150 languages as well as callers with special needs.

   2. Global Compliance logs each and every report. Whether you use the Integrity Hotline Phone number or website the Rowan University-Integrity Hotline allows you to report issues and concerns you may have (regarding but not limited to), unethical behavior, inappropriate conduct, bullying, harassment, and any other violation to Rowan University policies. This reporting process is secure and confidential. The organization prioritizes the speed with which reports must be addressed as follows:
      Priority A – Immediate
      Priority B – Moderate
      Priority C – Standard

   3. A committee of two University employees reviews each and every report. Should they believe the report involves factors that require greater perspective and independence they have access to outside investigators.

   4. The Reporting Compliance and Ethics Concerns (Whistleblower Policy) can be found on the Rowan University Compliance website: www.rowan.edu/compliance.

4. Protection from reprisal or retaliation

   1. Rowan University policy prohibits retaliation, harassment, intimidation or discrimination against individuals who make good faith reports of suspected wrongdoing. Any employee found to have retaliated against anyone who has made a good faith report shall be subject to appropriate disciplinary action up to and including termination of employment. Good faith reports that are not substantiated are protected under this policy.

   2. Complaints made in bad faith using falsified information is contrary to the intent and spirit of this policy, and may subject the reporter to disciplinary action up to and including termination.

   3. To make reports of immediate threats or danger, call 911. The Rowan University Alert Line should not be used for emergencies. There are other reporting methods for concerns which are summarized in Attachment 2.

5. Retaliation & Whistleblower Protection

   1. Reporting and Investigating Retaliation Allegations:

      1. Reporting: Anyone who has provided information who believes he or she is the subject of retaliation should report the facts supporting the allegations of retaliation to the Chief Compliance Officer; Interim Vice President of Human Resources, General Counsel, Ethics Liaison Officer (ELO) or the Alert Line.

         1. All investigations of alleged retaliation will be conducted as sensitively and expeditiously as possible. Due consideration will be given to existing grievance procedures under applicable collective bargaining agreements.

      2. Should an investigation lead the appropriate Rowan University authority to conclude that retaliation has been substantiated; the individual(s) responsible for committing the retaliation, in addition to any civil or criminal proceedings, shall be subject to disciplinary action up to and including termination.

      3. In accordance with New Jersey's Conscientious Employee Protection Act (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 identified in Attachment 1.

   2. The Conscientious Employee Protection Act Annual Notice is Attachment 1.

6. Sanctions

   1. Failure to comply with this policy may result in sanctions up to, and including, termination of employment or termination of a contractor's agreement.

7. Communications

   As Rowan University grows it is important to have 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 University to report Non-compliant activities. The document below provides a mechanism for anonymous and confidential reporting without any form of retaliation. It also provides a wide array of direction for all Rowan personal to address 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 – 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.

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1. New Jersey law prohibits an employer from taking any retaliatory action against an employee because the employee does any of the following:
   1. 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, constitutes improper quality of patient care;
   2. is fraudulent or criminal; or
   3. is incompatible with a clear mandate of public policy concerning the public health, safety or welfare or protection of the environment. N.J.S.A. 34:19-3.
1. Discloses, or threatens to disclose, to a supervisor or to a public body an activity, policy or practice of the employer or another employer, with whom there is a business relationship, that the employee reasonably believes 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 professional, reasonably believes constitutes improper quality of patient care;
2. Provides information to, or testifies before, any public body conducting 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, with whom there is a business relationship, or, in the case of an employee who is a licensed or certified health care professional, provides information to, or testifies before, any public body conducting an investigation, hearing or inquiry into quality of patient care; or
3. Provides information involving deception of or misrepresentation to, any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity.
4. Provides information regarding any perceived criminal or fraudulent activity, policy or practice of deception or misrepresentation which the employee reasonably believes may defraud any shareholder, investor, client, patient, customer, employee, former employee, retiree or pensioner of the employer or any governmental entity.
5. Objects to, or refuses to participate in, any activity, policy or practice which the employee reasonably believes:
2. The protection against retaliation, when a disclosure is made to a public body, does not apply unless the employee has brought the activity, policy or practice to the attention of a supervisor of the employee by written notice and given the employer a reasonable opportunity to correct the activity, policy or practice. However, disclosure is not required where the employee reasonably believes that the activity, policy or practice is known to one or more supervisors of the employer or where the employee fears physical harm as a result of the disclosure, provided that the situation is emergency in nature.
   
   CONTACT INFORMATION
   The following contact persons at Rowan University have been designated to answer your questions or provide information regarding your rights and responsibilities 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.

This notice must be conspicuously displayed.
Once each year, employers must distribute notice of this law to their employees.
If you need this document in a language other than English
or Spanish, please call (609) 292-7832.

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1. Rowan Human Resources Policies and Resources 
2. Office of Employee Equity - Contact, Interim Vice President for Human Resources, 856-256-4320
3. Rowan Human Resources Compensation 

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Employee Sexual Misconduct and Harassment Policy

1. Policy Prohibiting Discrimination in the Workplace and Educational Environment

Healthcare Compliance

1. Rowan University Office of Compliance and Corporate Integrity (856) 566-6136.

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Improper accounting and costing on sponsored projects

1. Rowan University Office of Sponsored Programs
2. Rowan-Virtua SOM Research Administration

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1. Facilities - Rowan University Environment Health & Safety Department 
2. Rowan-Virtua SOM Emergency Management – contact Thomas Boyle at (856) 566-6289/ boyletp@rowan.edu
3. Rowan-Virtua SOM Public Safety
4. Rowan University Radiation Safety Department 

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1. Information Resources & Technology 
2. Clinical Systems & Project Management

Violations of EPA regulations and Hazardous material releases

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