ROWAN UNIVERSITY POLICY 

Title: Reporting Compliance & Ethics Concerns ("Whistleblower Policy")
Subject: Ethics
Policy No:

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ELO:2014:01
Issuing Authority: Rowan President
Responsible Authority: Executive Vice President for Administration & Strategic Advancement
Adopted: August 21, 2014
Reviewed: August 21, 2014
Last Revision:

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

It is the policy of Rowan University that employees, students employed by the university, contractors, representatives or agents have a duty to report suspected wrongful conduct and they should be able to meet this duty without the fear of retaliation or reprisal. This policy gives everyone the opportunity to help Rowan achieve its mission.

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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 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; 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.

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

   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 Exhibit A 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.

VI. ATTACHMENTS 

1.  ATTACHMENT ATTACHMENT 1 -ANNUAL NOTICEAnnual Notice
2. ATTACHMENT 2 - TYPE OF ISSUEType of Issue

ATTACHMENT 1

 Annual Notice
Conscientious Employee
Protection Act
"Whistleblower Act"

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