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Rowan University Office of Compliance and Corporate Integrity

Rowan University

RowanSOM Compliance Program Manual

 

REPORTING SUSPECTED CRIMINAL BEHAVIOR


General Policy

As part of its commitment to ethical and legal conduct, RowanSOM expects its employees to bring to the attention of the Chief Compliance & Privacy Officer, or any of the people he or she designates, information they have about suspected violation of law by any RowanSOM employee or agent. Employees are required to come forward with any such information, without regard to the identity or position of the suspected offender. RowanSOM will treat the information in a confidential manner (consistent with appropriate evaluation and investigation) and will seek to ensure that no acts of retribution or retaliation will be taken against anyone for making a report Because failure to report criminal activity can itself be understood to condone the crime, we emphasize the importance of reporting. Failure to report knowledge of wrongdoing may result in disciplinary action against those who fail to report.

Complaint Procedure

A. Notification of Complaint
Information about known or suspected violations of any employee should be reported immediately.

B. Investigation
Reports of suspected unlawful activity will be investigated under the supervision of the Chief Compliance & Privacy Officer and the Office of Legal Management. Employees are expected to cooperate in the investigation of reported violations.

C. Confidentiality
To the extent practical and appropriate under the circumstances to protect the privacy of the persons involved, the Chief Compliance & Privacy Officer and the Office of Legal Management will not disclose the identity of anyone who reports a suspected violation of law or who participates in the investigation. Employees should be aware that the Chief Compliance & Privacy Officer, and those assisting him or her, are obligated to act in the best interest of RowanSOM, and do not act as personal representatives or lawyers for employees.

D. Protection Against Retaliation
Retaliation in any form against an individual who in good faith reports a violation of this policy or of law, even if the report is mistaken, or who assists in the investigation of a reported violation, is itself a serious violation of this policy. Acts of retaliation should be reported immediately and will be disciplined appropriately.

E. Discipline for Violations
All employees are expected to adhere to this policy. If the Chief Compliance & Privacy Officer concludes, after appropriate investigation, that this policy has been violated-whether by unlawful actions, condoning or failing to report information as to unlawful actions by others, retaliation against those who report suspected wrongdoing, or otherwise-he or she is authorized to recommend appropriate discipline, up to and including discharge.

Reporting Ethical or Compliance Concerns Policy