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A. Reporting Compliance and Ethics Concerns

1. The schools, departments and units that are a part of RowanSOM departments and units that bill federal or state programs for the provision of healthcare-related goods or services (“Related Healthcare Entity” or “Related Healthcare Entities”) 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 or RowanSOM 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.
2. To make a report, individuals may contact their direct manager or other members of their management team. In addition, individuals may call the RowanSOM Office of Compliance and Corporate Integrity at 856-566-6136, Rowan SOM Chief Compliance & Privacy Officer, General Counsel; Ethics Liaison Officers; or they may call the RowanSOM Compliance Hotline 1 855-431-9967.
3. The RowanSOM Compliance Hotline is available 24 hours a day/7days a week, via a toll free phone number, 1 855-431-9967. The RowanSOM Compliance Hotline accommodates 150 languages and includes special handling for challenged callers.
4. RowanSOM policy prohibits retaliation, harassment, intimidation or discrimination against individuals who make reports of suspected wrongdoing in good faith. Any employee found to have retaliated against another employee who reported actual or suspected wrongful conduct shall be subject to appropriate disciplinary action up to and including termination. The making of false, frivolous, or bad faith reports by an employee is contrary to the intent and spirit of this policy, and may subject the reporter to disciplinary action.
5. To make reports of immediate threats or danger, call 911.The RowanSOM Compliance Hotline should not be used for emergencies. There are other reporting methods for concerns which are summarized in attachment A.

B. Retaliation

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 & Privacy Officer; General Counsel or Ethics Liaison Officers (ELO).
   2. 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.
   3. Should an investigation lead the appropriate RowanSOM 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.

C. Sanctions

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

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