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Non-Retaliation Policy

Purpose

The general purpose of this policy is to comply with applicable federal and state laws prohibiting Retaliation, and to protect Nova Southeastern University (“NSU”) faculty, administrators, and employees (hereinafter referred to as “employees”) who make Good Faith Reports of suspected Improper Conduct by NSU employees. More specifically it:

  • encourages a culture that allows employees to meet their obligations to disclose suspected Improper Conduct;
  • informs employees how allegations of Improper Conduct may be disclosed;
  • Protects employees from reprisal by adverse employment action taken within NSU as a result of having disclosed suspected Improper Conduct; and
  • Provides employees who believe they have been subject to reprisal a process to seek relief from retaliatory acts that fall within the authority of NSU.

Definitions

Good Faith Report is defined in this policy to be an allegation of suspected Improper Conduct engaged in by a university employee (who is not also the Reporting Individual) based upon a good faith and reasonable belief that the conduct has both occurred and is wrongful under applicable law, regulation, and/or university policy. Communications or reports made in good faith do not disregard facts that would refute such communication or report and are not based upon intentional bias, malice, or other ill intent.

Improper Conduct is defined in this policy to be any act that violates a university policy, federal, state or local law or regulation being committed by a university employee. Improper Conduct includes, but is not limited to fraud, theft, bribery, misuse of university property, or coercion by a university faculty or staff member to commit an unlawful act.

Reporting Individual is defined by this policy to be any employee who makes a Good Faith Report.  

Retaliation is defined by this policy to be an adverse action, including but not limited to harassment, disciplinary action, demotion,  suspension, reassignment, or termination, against any employee for making a Good Faith Report, opposing an unlawful practice, participating in an investigation involving a Good Faith Report, or enforcing this policy.

Policy Statement

NSU employees are expected to abide by federal, state and local laws and regulations, as well as university policies. As provided for in NSU’s Code of Conduct, NSU employees are expected to report instances of suspected Improper Conduct that come to their attention.

Employees are encouraged to continue to report suspected Improper Conduct through regular lines of communication. In many circumstances the best place to raise a concern or question is with your supervisor, or with a senior manager in your department. These individuals need to know about concerns that arise in the area under their management, and should be in the best position to help you resolve concerns at a local level.

We realize, however, that there may be circumstances when employees are not comfortable reporting a concern in this manner. It is for such circumstances that we have selected NAVEX Global to provide employees with an anonymous method for reporting your good faith concerns. To facilitate this, an external hotline provider, NAVEX Global, has been selected to provide employees with an anonymous method for reporting good faith concerns that may involve improper conduct including violations of law or university policies and procedures. The Ethics and Compliance Reporting Hotline at 888-609-NOVA is toll free, anonymous, and available 24 hours, 7 days a week. The Ethics and Compliance Reporting Hotline is not to be used to bring knowingly and intentionally false allegations of Improper Conduct. It is an expectation of the policy that all reports will be made in good faith as defined in this policy.

No NSU employee may interfere with the Good Faith Report of suspected Improper Conduct; no Reporting Individual who makes such a Good Faith Report shall be subject to Retaliation, including harassment or any adverse employment consequence, as a result of making a report. NSU will take whatever action is necessary and appropriate to address a violation of this policy.

Complaints of Retaliation

Employees who believe that they have been Retaliated against may submit a report to their immediate supervisor, senior manager in your department, or with the Office of Human Resources. Employees are not obligated to consult or submit a report to their immediate supervisor or senior manager in his/her department before bringing the matter to the attention of the Office of Human Resources. Regardless of the designated representative who receives an employee assertion of possible retaliation, the matter must be reported to the Office of Human Resources.

Alternatively, the employee may report assertions of possible Retaliation anonymously, using the Ethics and Compliance Reporting Hotline at 888-609-NOVA. The Ethics and Compliance Reporting Hotline is not to be used to bring knowingly and intentionally false allegations of Improper Conduct. It is an expectation of the policy that all reports will be made in good faith as defined in this policy.

As noted above, the Office of Human Resources will receive employee assertions of possible Retaliation. The Office of Human Resources will take whatever action is necessary and appropriate to address a violation of this policy.

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