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

      1. University Ethics Liaison Officer (ELO), established under Executive Order 24 (Christie). The University's ELO is Robert Zazzali who is located on the Glassboro Campus at Bole Hall. He can be reached at 856-256-4110. The Deputy ELO is Ray Braeunig who is located on the Stratford Campus in the University Education Center (UEC-1034). He can be reached at 856-566-6136. 

      2. University Chief 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. University Equity and Diversity Office. Johanna Velez-Yelin is Assistant Vice President Equity and Diversity and can be reached at the Glassboro Campus in Linden Hall. She can be reached at 856-256-5440. 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 Disabilities Act, Title IX Compliance, Rowan University Workplace Violence Policy, and EEO Compliant Search Practices.

    2. 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.

    3. 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.

    4. 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.

    5. 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 Officers; or they may call the Rowan University Integrity Line.

  3. Integrity hotline, 855-431-9967

    1. 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 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. Visit www.rowan.edu/compliance to learn more about Rowan's policy on Reporting Compliance and Ethics Concerns, the protection afforded to employees who report violations and rights of individuals accused of wrongdoing

  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 Exhibit B.

  5. Retaliation & Whistleblower Protection

    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; Assistant Vice President Equity and Diversity; General Counsel, Ethics Liaison Officers (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 Exhibit A below.

      The Conscientious Employee Protection Act Annual Notice is Exhibit A (below)

  6. 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.

  7. Communications

    Notices:Posters will be placed in each Human Resource site for each Rowan University unit/school. See below Exhibit A – 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.

...

Este aviso se debe exponer a la vista de todos.
Una vez por año, los empleadores deben de distribuir un aviso de esta ley a sus empleados. Si necesita este documento en algún otro idioma que no sea inglés o español, sírvase llamar al (609) 292-7832. Posiblemente, una carga nominal puede ser cobrada.

Exhibit B

Type of Issue

Where to go for support/direction and how to report an issue

Abuse/neglect of minors

  1. 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 report it to the New Jersey Division of Child Protection and Permanency, formerly the Division of Youth and Family Services (DYFS) at 1-877-NJABUSE (1-877-652- 2873).
  2. Anyone who suspects that a minor has been subject to abuse or neglect must immediately notify the Rowan University Police Department (RUPD) at 856-757-7777.
  3. Website Page – www.rowan.edu/compliance
  4. Protection of Minors Policy -{*}{+}http://www.rowan.edu/studentaffairs/communitystandards/documents/RowanUniversityStudentHandbook2013-2014.pdf#minors+*pdf

Accident/Injury

  1. In an Emergency, call 911
  2. Job-related injury reporting- http://www.rowan.edu/hr/pension/workerscomp.html
  3. Injury Reporting Form for Student or the Public - http://www.rowan.edu/open/studentaffairs2/healthcenter/confidentiality.html

Alcohol and Drug Use; Alcohol on Campus

    1. The resources available to employees and supervisors relating to alcohol and drug use/abuse may be accessed in Rowan University Policy- http://www.rowan.edu/studentaffairs/main_office/files/aodguide.pdf
    2. Employees are encouraged to seek assistance through the Faculty and Staff Assistance Program if they believe they may have an alcohol or other drug abuse problem- http://www.rowan.edu/studentaffairs/main_office/files/aodguide.pdf
      http://www.rowan.edu/som/hr/documents/orientation.pdf

Animal Research Violations of NIH, USDA, AAALAC Regulations-
 http://www.rowan.edu/open/provost/research
http://srintra.rowan.edu/viv/links.cfm - animal welfare regulations 

  1. The Office of Research and Sponsored Programs provides information relating to the use of animal in research. To contact the Office of Research and Sponsored Programs staff, please follow this link: http://www.rowan.edu/provost/research/Integrity_and_compliance/Integrity_and_compliance.cfm

Conflict of Interest violation of DHHS, FDA, NSF or other Federal Agency Regulations

    1. Contact the Office of the Vice President of Research and Economic Development.
      http://www.rowan.edu/open/provost/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, Banner, e-mail)

  1. Rowan University Information Resource Technology – http://www.rowan.edu/toolbox/about/
  2. RowanSOM Information Resource Technology - http://www.rowan.edu/som/ist/index.html
  3. Disability: Americans with Disabilities Act (faculty-related)- http://www.rowan.edu/equity
  4. Academic Labor Relations- contact Robert Zazzali @ 856-256-4110 or zazzali@rowan.edu

Disability: Americans with Disabilities Act (staff-related)

  1. Office of Equity and Diversity- http://www.rowan.edu/equity

Disability: Americans with Disabilities Act (student-related)

  1. Rowan University Academic Success Center - http://www.rowan.edu/studentaffairs/asc
  2. RowanSOM Office of Student Affairs - http://www.rowan.edu/som/education/student_affairs/index.html

Discrimination

  1. Policy Prohibiting Discrimination and Harassment- http://www.rowan.edu/equity
  2. Office of Equity and Diversity - http://www.rowan.edu/equity
  3. Rowan University Office of Community Standards & Commuter Services – http://www.rowan.edu/studentaffairs/communitystandards/handbook.html
  4. Rowan SOM Education Handbook-http://www.rowan.edu/som/education/undergraduate_medical/documents/StudentHandbook.pdf

Export Controls (Research)- www.rowan.edu/compliance, click research tab

  1. Rowan University Office of the Vice President of Research – http://www.rowan.edu/open/provost/research/

Fair Labor Standards Act and Overtime Provisions

  1. UHR Policies and Resources - http://www.rowan.edu/hr/documents/orientation.pdf
  2. Office of Labor Relations - contact Ken Kuerzi @ (856) 256-4138 or kuerzi@rowan.edu
  3. UHR Compensation - http://www.rowan.edu/hr/documents/orientation.pdf

Fraud (Financial)

  1. Internal Audit Department

Harassment

  1. Policy Prohibiting Discrimination and Harassment - http://www.rowan.edu/equity
  2. Office of Equity and Diversity: http://www.rowan.edu/equity
    1. Harassment: A Guide for Faculty- http://www.rowan.edu/equity
    2. Harassment: A Guide for Staff- http://www.rowan.edu/equity
    3. Harassment: A Guide for Students- http://www.rowan.edu/equity/titleix

Student Sexual Misconduct and Harassment Policy
http://www.rowan.edu/equity/TITLEIX 

  1. Code of Student Conduct- http://www.rowan.edu/som/education/undergraduate_medical/documents/StudentHandbook.pdf
  2. Office of Student Conduct handles complaints against students arising out of their conduct as students http://www.rowan.edu/som/education/undergraduate_medical/documents/StudentHandbook.pdf

Employee Sexual Misconduct and Harassment Policy-

    1. www.rowan.edu/equity

Healthcare Compliance

  1. The RowanSOM Office of Compliance and Corporate Integrity- www.rowan.edu/compliance or call 856-566-6136

Human Subject Research Violations of DHHS/OHRP, FDA and other Federal Regulations pertaining to human subject research

  1. The Office of the Vice President of Research and Economic Development IRB and Compliance Administrator - http://www.rowan.edu/som/research/admin.html

Improper accounting and costing on sponsored projects

  1. Rowan University Office of Sponsored Programs – http://www.rowan.edu/open/provost/grants/
  2. RowanSOM Research Administration- http://www.rowan.edu/som/research/admin.html
  3. Internal Audit Department – James J. Rowan, Chief Internal Auditor – (856) 256-5110 or rowanj@rowan.edu

Improper document of or billing for healthcare goods or services

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

Laboratory Safety Violations

  1. Rowan University Environment Health and Safety -http://www.rowan.edu/adminfinance/facilities/ehs/TrainingResourcesforSupervisors.php
  2. RowanSOM Emergency Management – contact Thomas Boyle at (856) 566-6289/ boyletp@rowan.edu or Department of Public Safety – http://www.rowan.edu/som/public_safety/index.html

Misconduct in Research including Falsification of Documents/Records

  1. University Policy for Dealing with Allegations of Misconduct in Research – http://www.rowan.edu/compliance, click research tab

Open Public Meetings Act –

  1. Office of the Secretary of the University – http://www.rowan.edu/president/board/tentativeagenda.html

Open Public Records Act –

  1. Office of the Secretary of the University – http://www.rowan.edu/president/board/tentativeagenda.html

Public Safety/Emergency Management

  1. http://www.rowan.edu/safety/

Radiation Safety Violation of NRC or DCRA Regulations

  1. Laboratory Safety and Environmental Programs Radiation Safety Group - http://srintra.rowan.edu/RadSafety.cfm

Records Management (e.g. document retention schedules, archiving documents)

  1. www.rowan.edu/compliance - Policies- Records Management

Division of Administration and Public Safety- http://www.rowan.edu/safety 
Records: Loss of records; inability to find records; improper release, disclosure or access to records
 http://www.rowan.edu/adminfinance/records
http://www.rowan.edu/som/hr/documents/orientation.pdf

    1. Depending on the type of records, you may contact the following offices:

    2. RowanSOM Business or Financial Information: Office of the Secretary of the University, Custodian of Records
    3. Student Information: The Office of Student Affairs Compliance - http://www.rowan.edu/som/education/student_affairs/contact.html
      http://www.rowan.edu/equity/titleix
       http://www.rowan.edu/provost/registrar/
    4. Patient Information - RowanSOM Privacy Officer (856-566-6136) or ALERTLINE 1-855-431-9967, www.rowan.edu/compliance
    5. Non-public personal information of any individual, including credit card information, social security numbers, driver's license numbers, etc. – Compliance ALERTLINE-1-855-431-9967.

Director of Information Protection and Security or go to the Information Protection and Security website Research Compliance-

  1. Rowan University Information Resource Technology – http://www.rowan.edu/toolbox/about/
  2. Rowan University Vice President of Research – http://www.rowan.edu/open/provost/research/

Research: Sponsored Project Billing and Reporting

  1. Rowan University Office of Sponsored Program - http://www.rowan.edu/open/provost/grants/
  2. Internal Audit Department – James J. Rowan, Chief Internal Auditor – (856) 256-5110 or rowanj@rowan.edu

RowanSOM Biomedical and Health Sciences Compliance Issues

  1. The RowanSOM Office of Compliance and Corporate Integrity- www.rowan.edu/compliance or call (856) 566-6136

Sexual Harassment

    1. Policy Prohibiting Discrimination and Harassment - http://www.rowan.edu/equity{+}, or http://www.rowan.edu/som/hr/documents/orientation.pdf+
    2. Office of Equity and Diversity: http://www.rowan.edu/equity
      1. Harassment: A Guide for Faculty- http://www.rowan.edu/equity
      2. Harassment: A Guide for Staff- http://www.rowan.edu/equity
      3. Harassment: A Guide for Students- http://www.rowan.edu/equity/titleix
        http://www.rowan.edu/studentaffairs/communitystandards/handbook.ht

Student Billings

  1. RowanSOM Office of Student Accounting, Billing and Cashiering - http://www.rowan.edu/adminfinance/policies_procedures
  2. http://www.rowan.edu/som/education/student_affairs/index.html

Student Loan Abuses

  1. Rowan University Office of Financial Aid - http://www.rowan.edu/provost/financialaid/
  2. RowanSOM Office of Financial Aid – http://www.rowan.edu/som/financialaid/Apply_JUMP.html

University Property: Loss or Theft

  1. If the loss or theft involves the loss of records or information, see Records (link to the Records, Loss of Records below.)- http://www.rowan.edu/safety/lostandfound/index.php

Victim Assistance (and violence prevention)

  1. In an emergency, dial 911.
  2. Violence Prevention and Victim Assistance

Violation of OSHA, HFPA, BOCA, NRC, and FDA regulations

  1. Facilities-Rowan University Environment Health & Safety Department - http://www.rowan.edu/adminfinance/facilities/ehs/
  2. RowanSOM Emergency Management – contact Thomas Boyle at (856) 566-6289/ boyletp@rowan.edu
  3. Department of Public Safety – http://www.rowan.edu/som/public_safety/index.html
  4. Rowan University Radiation Safety Department - http://srintra.rowan.edu/RadSafety.cfm

Violation of System Security

  1. Rowan SOM Information Resources & Technology - http://www.rowan.edu/som/ist/index.html
  2. Rowan University Clinical Systems & Project Management –http://www.rowan.edu/toolbox/about

Violations of EPA regulations and Hazardous material releases- http://www.state.nj.us/dep

  1. Emergency call 911

Worker's Compensation Laws

  1. New Jersey Department of Labor- http://lwd.state.nj.us/labor/index.html

Workplace Violence- http://www.rowan.edu/equity

    1. In an emergency, or if you experience or witness imminent or actual violence involving weapons or potential injuries, call 911.
    2. 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 lieu thereof, to the appropriate Designated University Representative.