Preface:
As Rowan University grows it is important to have processes in place to ensure concerns are addressed on a timely and efficient basis.
Effective communication is necessary for a University to swiftly communicate information to personnel 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 Personnel to address concerns.
Please read and keep this information available to you.
Table of Contents:
Pages
Reporting Compliance and Ethics Concerns (Whistleblower Policy) 4 – 8
EXHIBIT A (Annual Notice-Whistleblower Act) 9 – 12
EXHIBIT B (Where to go for specific policies and information) 13 – 19
Title: Reporting Compliance & Ethics Concerns
Policy No: OCCI:2014:01
Applies: All Rowan University. All Schools, Units, Departments & Employees
Issuing Authority: Rowan President
Responsible Authority: Executive Vice President for Administration & Strategic Advancement
Adopted: August 21, 2014
Reviewed August 21, 2014
Amended
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.
II. Accountability
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.
The University complies with the following related documents:
A Corporate Integrity Agreement between the Office of Inspector General of the Department of Health and Human Services and the University of Medicine and Dentistry of New Jersey, September 25, 2009 to September 25, 2014, as amended by a Letter Agreement, UMDNJ-RowanSOM dated 5/1/2013.
B The Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. §1320a- 7b (the "Anti-kickback Statute"),
C Stark Law, 42 CFR §§ 411.350 – 411.389
D New Jersey's Conscientious Employee Protection Act (N.J.S.A. 34.19-1 et seq., also known as the "Whistleblower Act")
E Sarbanes-Oxley Sarbanes-Oxley not only prohibits retaliating against whistle blowers (SOX section 806), it also affirmatively requires companies to set up hotlines or other "procedures" for the "confidential, anonymous submission of employee complaints and concerns" about audit/accounting fraud (SOX section 301).
IV. The Policy
A. 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 reprisal 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 suspected wrongdoing. If something seems wrong, it may be, so employees are encouraged to report it.
B. Reporting Compliance And Ethics Concerns
As always, report immediate threats or danger by calling 911. Other University contacts include:
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.
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.
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.
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.
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 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.
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:
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.
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
C. Protection From Reprisal Or Retaliation
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.
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.
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.
D. Retaliation & Whistle blower Protection
Reporting and Investigating Retaliation Allegations
E. 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.
F. Communications
.
V. EXHIBITS
A. Exhibit A – Annual Notice
Conscientious Employee
Protection Act
"Whistleblower Act"
Employer retaliatory action; protected employee actions; employee responsibilities
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: Robert Zazzalli
Address:Bole Hall
Telephone Number: (856) 256-4110
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.
AD-270 (3/06)
La Ley de protección al
empleado consciente
"Ley de protección del denunciante"
Acciones de represalia del empleador; protección de las acciones del empleado
Información del Contacto
La persona siguiente para ha sido designada a contestar sus preguntas
o, proporcionar información adicional relacionada con sus derechos y
responsabilidades según lo indica esta ley (N.J.S.A. 34:19-4):
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.
B. Exhibit B
Type of Issue
Where to go for support/direction and how to report an issue
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
RowanSOM Research Administration- http://www.rowan.edu/som/research/admin.html
Internal Audit Department – James J. Rowan, Chief Internal Auditor – (856) 256-5110 or rowanj@rowan.edu
Rowan University Environment Health and Safety -http://www.rowan.edu/adminfinance/facilities/ehs/TrainingResourcesforSupervisors.php
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
University Policy for Dealing with Allegations of Misconduct in Research – http://www.rowan.edu/compliance, click research tab
Office of the Secretary of the University – http://www.rowan.edu/president/board/tentativeagenda.html
Office of the Secretary of the University – http://www.rowan.edu/president/board/tentativeagenda.html
Laboratory Safety and Environmental Programs Radiation Safety Group - http://srintra.rowan.edu/RadSafety.cfm
Division of Administration and Public Safety- http://www.rowan.edu/safety
Depending on the type of records, you may contact the following offices:
Rowan University Information Resource Technology – http://www.rowan.edu/toolbox/about/
Rowan University Vice President of Research – http://www.rowan.edu/open/provost/research/
Rowan University Office of Sponsored Program - http://www.rowan.edu/open/provost/grants/
Internal Audit Department – James J. Rowan, Chief Internal Auditor – (856) 256-5110 or rowanj@rowan.edu
The RowanSOM Office of Compliance and Corporate Integrity- www.rowan.edu/compliance or call (856) 566-6136
Policy Prohibiting Discrimination and Harassment - http://www.rowan.edu/equity{+}, or http://www.rowan.edu/som/hr/documents/orientation.pdf+
Office of Equity and Diversity: http://www.rowan.edu/equity
RowanSOM Office of Student Accounting, Billing and Cashiering - http://www.rowan.edu/adminfinance/policies_procedures
http://www.rowan.edu/som/education/student_affairs/index.html
Rowan University Office of Financial Aid - http://www.rowan.edu/provost/financialaid/
RowanSOM Office of Financial Aid – http://www.rowan.edu/som/financialaid/Apply_JUMP.html
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
In an emergency, dial 911.
Violence Prevention and Victim Assistance
Rowan SOM Information Resources & Technology - http://www.rowan.edu/som/ist/index.html
Rowan University Clinical Systems & Project Management – http://www.rowan.edu/toolbox/about
Emergency call 911
New Jersey Department of Labor- http://lwd.state.nj.us/labor/index.html
In an emergency, or if you experience or witness imminent or actual violence 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 lieu thereof, to the appropriate Designated University Representative.
All regulations and procedures are subject to amendment.