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Whistleblower and Retaliation Compliance

Stevenson University is committed to complying fully with all federal, state, and local laws, rules, and regulations that are applicable to private nonprofit organizations of higher education.

Stevenson University encourages its students, faculty, officers, trustees, employees, job applicants, former employees, volunteers, contractors and vendors (the Stevenson Community) to come forward if they learn of information or have concerns about possible unlawful, fraudulent or unethical behavior on University property, in University matters, or in any way associated with Stevenson University.

To this end, the University has adopted the following Whistleblower and Anti-Retaliation Policies in order to assure the Stevenson Community that they may safely express their good faith concerns about possible University-related unlawful, fraudulent or unethical activity responsibly without fear of retaliation by Stevenson University for reporting such information or concerns in the procedures under this policy on compliance.

Whistleblower Policy

The purpose of this Whistleblower & Retaliation Compliance Policy is to ensure the University’s compliance with all applicable provisions of the False Claims Act, federal Occupational Safety and Health Act (OSHA); Maryland Occupational Safety and Health Act (MOSHA); Title IX of the Education Amendments of 1972; the Clery Act; the Sarbanes-Oxley Act (to the extent that it applies to Stevenson University); and applicable federal and state rules and regulations promulgated thereunder. The University advocates responsible reporting of any conduct that is reasonably believed to be in non-compliance with applicable law and will protect from retaliation members of the Stevenson Community who follow the reporting procedures outlined in this Policy or otherwise exercise their rights under applicable law.

Whistleblower Protections for Reporting of Resources-Related Prohibited Acts

The University prohibits unlawful and/or fraudulent conduct of any kind by members of the Stevenson Community with respect to University funds, resources and/or property (Resources- Related Prohibited Acts). These Resources-Related Prohibited Acts include, but are not limited to:

  • An abuse of authority, gross misconduct, misappropriation, bribery, forgery, gross waste, fraud, or misrepresentation in financial reporting regarding University funds, resources, or property;
  • A substantial and specific danger to public health and/or safety; or
  • A violation of federal, state, or local law, rules, or regulations relating in any way to University funds, resources, or property.

Members of the Stevenson community who are aware of or in good faith suspect the occurrence of any Resources-Related Prohibited Acts that relate in any way to the University are encouraged to report their concerns in accordance with the procedures set forth below. By adhering to the procedures set forth below, they can be assured that the University policy prohibits reprisals, retaliation, or other negative consequences of any kind by reporting possible Resources-Related Prohibited Acts. (Members of the Stevenson Community who report their concerns about Resources-Related Prohibited Acts directly to governmental entities will be afforded the same protections under this Whistleblower Policy as those who follow the recommended reporting procedures outlined below.)

Process for Disclosure of Resources-Related Prohibited Acts

A member of the Stevenson community who has information or concerns about Resources-Related Prohibited Acts is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. The University encourages any person who in good faith believes or suspects that Resources-Related Prohibited Acts have been committed to report immediately his/her concerns to the President, Vice President, Dean or Director of the applicable University department, or to the confidential Ethics Hotline via 24/7 access by phone (1-800-765-3277) or website (www.bhsonline.com).  All reports of Resources-Related Prohibited Acts will be considered confidential to the fullest extent allowed by law and to the fullest extent practicable, and will be shared with others only on a “need-to-know” basis. Reports may be made anonymously; however, any investigation may be hampered or impracticable if the reporting individual cannot be identified and questioned about the allegations and related facts.

The University prohibits all members of the Stevenson community from engaging in Resources- Related Prohibited Acts. In the event a member of the Stevenson community learns of any such Resources-Related Prohibited Acts, he/she is expected, as soon as reasonably practicable, to follow the disclosure procedures set forth in this Policy. As stated above, the University strictly prohibits any retaliation (including, but not limited to, harassment, adverse employment action, academic or educational consequences, and/or physical, mental, or reputational harm or threats thereof) by any person (including all members of the Stevenson Community) against any individual for reporting a reasonable belief or suspicion of Resources-Related Prohibited Acts, even if that good faith belief is later determined to have been incorrect.

Follow-up on Reports of Resources-Related Prohibited Acts

After receiving a report, the Dean, Director or Vice President shall consult with the President or his/her designee, typically the Chief Financial Officer and Vice President, Human Resources, and take whatever action they determine to be appropriate under the law. Such consultation may include disclosure to legal counsel and/or financial advisors. In the case of disclosure of Resources-Related Prohibited Acts involving the President of the University, the disclosure shall be directed to the Chairman of the Stevenson University Board of Trustees or his/her designee. The Chairman shall consider the disclosure in consultation with the Board and take whatever action is appropriate under the law. Such consideration may include disclosure to legal counsel and/or financial advisors.

Complaints of Retaliation as a Result of Disclosure of Resources-Related Prohibited Acts

If a member of the Stevenson Community believes that he/she has been threatened or retaliated against for disclosing information regarding Resources-Related Prohibited Acts under this Policy, then he/she should file a written complaint to the University’s President, Vice President, Dean, or Director seeking remedial action. For purposes of this policy, “retaliation” may include, but is not limited to, corrective action; failure to hire, promote or retain; adverse changes in compensation; harassment; or any discernable action related to wages, hours, conditions of employment or volunteer service; adverse academic or educational consequences; or physical, mental or reputational harm or threats thereof, any of which are reasonably perceived to be causally connected to the protected disclosure. Any employee who retaliates against someone who has made a report in good faith under this Policy is subject to disciplinary action, up to and including dismissal from the University.

Whistleblower Protections for Reporting Title IX/Clery Act-Related Prohibited Acts

Title IX of the Education Amendments of 1972 (Title IX) protects the Stevenson Community against all forms of sex-based discrimination, including: sexual harassment, dating and domestic violence, and other forms of sexual misconduct, stalking and retaliation. Members of the Stevenson Community who experience discrimination or harassment based on sex or gender should contact the Stevenson University Title IX Coordinator. The Title IX Coordinator is also responsible for ensuring that sex offenses reportable under the Clery Act are reported in a timely manner to the Campus Police. An optional form for making the report can be found on the SUNow Portal. Data collected for Clery Act reporting is used to increase public safety, not to identify the victim; therefore, victim identifying information is not required. (Members of the Stevenson Community who report their concerns about Title IX/Clery Act-Related Prohibited Acts directly to governmental entities will be afforded the same protections under this Whistleblower Policy as those who follow the recommended reporting procedures outlined below.)

Reporting to Title IX Coordinator

If a Stevenson University administrator, faculty or staff member receives an oral or written complaint of sex-based discrimination or sexual harassment, dating or domestic violence, or other forms of sexual misconduct, stalking or retaliation involving a member of the Stevenson Community, such person has an affirmative responsibility to promptly inform Stevenson University’s Title IX Coordinator, David C. Jordan, (443)334-2176, dcjordan@stevenson.edu.  

Stevenson students are also encouraged to report any sex-based discrimination or sexual harassment, dating or domestic violence, or other forms of sexual misconduct, stalking or retaliation involving a member of the Stevenson Community. The Title IX Coordinator will respond to the report in accordance with Stevenson University’s policy and procedures. Employees of Stevenson who experience or are aware of such sex-based discrimination or sexual harassment or other unlawful forms of discrimination should follow the Harassment Reporting Procedures set forth in Volume II – Campus Compliance Policies, section 2.4.

Title IX/Clery Act Retaliation Prohibited

The University strictly prohibits any retaliation (including, but not limited to, harassment, adverse employment action, and/or academic or educational consequences) by any person (including all members of the Stevenson Community) against any individual for reporting a reasonable belief or suspicion of sex-based discrimination or sexual harassment, dating or domestic violence, or other forms of sexual misconduct, stalking or retaliation, even if that good faith belief is later determined to have been incorrect.

Complaints of Retaliation as a Result of Disclosure of Title IX and/or Clery Act Violations

If a member of the Stevenson Community believes that he/she has been threatened or retaliated against for reporting information regarding sex-based discrimination or sexual harassment, dating or domestic violence, or other forms of sexual misconduct, stalking or retaliation under this policy, then he/she should promptly inform Stevenson University’s Title IX Coordinator, David C. Jordan, (443)334-2176, dcjordan@stevenson.edu.  If for any reason that member feels uncomfortable voicing his/her concerns to the Title IX Coordinator, then he/she should contact the University’s President, Vice President, Dean, or Director of the applicable University department. For purposes of this policy, “retaliation” may include, but is not limited to, corrective action; failure to hire, promote or retain; adverse changes in compensation; harassment; or any discernible action related to wages, hours, conditions of employment or volunteer service; adverse academic or educational consequences; or physical, mental or reputational harm or threats thereof, any of which are reasonably perceived to be causally connected to the protected disclosure. Any employee who retaliates against someone who has made a report in good faith under this policy is subject to disciplinary action, up to and including dismissal from the University.

Whistleblower Protections for Reporting Health and Safety-Related Prohibited Acts

The University complies with all applicable occupational safety and health standards issued under the federal Occupational Safety and Health Act (OSHA); Maryland Occupational Safety and Health Act of 1973 (MOSHA). The University prohibits all violations of occupational safety and health standards, rules, regulations and orders issued under MOSHA (Health and Safety-Related Prohibited Acts) applicable to the University. Members of the Stevenson Community who are aware of or in good faith suspect the occurrence of any Health and Safety-Related Prohibited Acts are encouraged to report their concerns in accordance with the procedures set forth below. They can be assured that they will not experience reprisals, retaliation, or other negative consequences of any kind from the University by adhering to the procedures set forth below for reporting Health and Safety-Related Prohibited Acts. (Members of the Stevenson Community who report their concerns about Health and Safety-Related Prohibited Acts directly to governmental entities will be afforded the same protections under this Whistleblower Policy as those who follow the recommended reporting procedures outlined below.)

Process for Disclosure of Health and Safety-Related Prohibited Acts

The University encourages any person who in good faith believes or suspects that Health and Safety-Related Prohibited Acts have been committed to report immediately his/her concerns to the Assistant Vice President, Facilities & Campus Services; President; Vice President; Dean or Director of the applicable University department, or to the confidential Ethics Hotline vis 24/7 access by phone (1-800-765-3277) or website (www.bhsonline.com). All reports of Health and Safety-Related Prohibited Acts will be considered confidential to the fullest extent allowed by law and to the fullest extent practicable, and will be shared with others only on a “need to know” basis. Reports may be made anonymously; however, any investigation may be hampered or impracticable if the reporting individual cannot be identified and questioned about the allegations and related facts.

The University requires that all members of the Stevenson Community refrain from engaging in Health and Safety-Related Prohibited Acts. In the event a member of the Stevenson Community learns of any such Health and Safety-Related Prohibited Acts, he/she is expected to, as soon as reasonably practicable, follow the disclosure procedures set forth in this Policy. (Employees or their representatives also have the right to file a complaint directly with the Commissioner of the Maryland Department of Labor, Licensing and Regulation (DLLR) requesting an inspection if they believe unsafe or unhealthful conditions exist in their workplace. The Commissioner will withhold names of employees complaining upon request. Members of the Stevenson Community who report their concerns about Health and Safety-Related Prohibited Acts directly to government entities will be afforded the same protections under this Whistleblower Policy as those who follow the recommended reporting procedures outlined herein.)

As stated above, the University strictly prohibits any retaliation (including, but not limited to, harassment, adverse employment action, and/or academic or educational consequences) by any person (including all members of the Stevenson Community) against any individual for reporting a reasonable belief or suspicion of Health and Safety-Related Prohibited Acts, even if that good faith belief is later determined to have been incorrect.

Follow-up on Reports of Health and Safety-Related Prohibited Acts

After receiving a report, the Dean, Director, or Vice President shall consult with the President or his/her designee, typically the Assistant Vice President, Facilities & Campus Services. The University will investigate, inspect, and, if necessary, take reasonable remedial action designed to correct reported Health and Safety-Related Prohibited Acts.

Complaints of Retaliation as a Result of Disclosure of Health and Safety-Related Prohibited Acts

If a member of the Stevenson Community believes that he/she has been threatened or retaliated against for disclosing information regarding Resources-Related Prohibited Acts under this Policy, then he/she should file a written complaint to the University’s President, Vice President, Dean, or Director requesting an appropriate remedy. For purposes of this Policy, “retaliation” may include, but is not limited to, corrective action; failure to hire, promote, or retain; adverse changes in compensation; harassment; or any tangible action related to wages, hours, conditions of employment or volunteer service; adverse academic or educational consequences; or physical, mental or reputational harm or threats thereof, any of which are reasonably perceived to be causally connected to the protected disclosure. Any employee who retaliates against someone who has made a report in good faith under this Policy is subject to disciplinary action, up to and including dismissal from the University.

Whistleblower-Related Auditing Processes

The University is audited each year by an independent accounting firm that reviews the following documents: Financial Statements, Schedule of Federal Awards (A133), and the 403(b) Retirement Program. The University does not utilize the services of the selected firm for any other general non-auditing services.

The Audit, Finance and Property Committee of the Board of Trustees meets with the audit partner and senior manager from the firm on a minimum of an annual basis to discuss audit results and current business, management, and governance practices in private, nonprofit higher education. The Audit, Finance and Property Committee receives the most current financial and budget reports at each meeting, prepared by the University’s business office, which monitors and provides monthly financial reports to the President. The Board of Trustees has an Investment sub-committee that is responsible for the selection and monitoring of the University’s investment holdings. This sub-committee is comprised of one or more trustees who are Certified Public Accountants with considerable financial expertise. No voting member of the Board of Trustees receives any financial compensation from the University. The President serves as a non-voting ex-officio member to the Board of Trustees. All University staff members who serve to support functions of the Board of Trustees do not participate in voting.

Whistleblower-Related Records Retention and Destruction

Stevenson University shall maintain all operating records, including and not limited to financial, tax, license, permits, human resources and budget records, for a period of no less than the time required by applicable laws or regulations. Failure to retain those records for those minimum periods could subject the University to penalties or fines, cause the loss of rights, obstruct justice, spoil potential evidence in a lawsuit, place the University in contempt of court, or seriously disadvantage the University in litigation. University personnel should exercise the highest degree of care in preserving documents that further in any way the interests of University.  In the event University personnel has any doubt about the need to preserve a particular record, he/she is required to consult with his or her supervisor for further direction. Stevenson University requires strict and exacting compliance with its Records Retention Policy.  Failure to comply with this Records Retention Policy may result in disciplinary action, up to and including dismissal from the University.

Records Associated with Litigation and/or Investigations

All records (including, but not limited to, paper records, electronic files, email, voicemail and text messages) relevant to litigation, potential litigation, or government investigations must be preserved. If an employee believes, or if the University informs them, that University records are relevant to litigation, potential litigation, or government investigations (i.e., a conflict, dispute or claim that could result in judicial or administrative agency investigation or legal proceeding), then the employee must preserve those records until the University advises them in writing that such records are no longer needed. This requirement supersedes any previously or subsequently established retention schedule for those University records. Employees are to retain indefinitely any and all records that reflect or relate in any way to any dispute or controversy involving a customer, vendor, donor, employee, student, etc. of the University.  If an employee believes that they are in possession of any such records, or have a question regarding the possible applicability of the University’s requirement to preserve all litigation-related and investigation-related records, they should contact the Vice President, Human Resources to discuss all questions or concerns.

Record Destruction

Records that are permitted by law to be destroyed shall be destroyed in a manner that ensures no personal identifying information remains. It is a crime to intentionally alter, mutilate, conceal, cover up, falsify, make a false entry in, or destroy any record related to any governmental proceeding or investigation, or to cause someone else to do the same. Violators of this Record Destruction Policy will be subject to disciplinary action, up to and including termination and/or dismissal from the University.

The Chief Financial Officer shall have primary oversight of this policy. Each Vice President, Dean, Chair or Director of the applicable University department shall have responsibility for records retention and destruction compliance for all records maintained in or by his or her respective department. The Audit, Finance and Property Committee of the Board of Trustees retains the authority to conduct periodic audits of departmental records retention and destruction practices.

Prohibition Against Unlawful Retaliation

There are many laws and regulations that explicitly prohibit organizations such as Stevenson University from retaliating against individuals who exercise certain statutory rights.

Specifically, Stevenson University will not retaliate in any way against an individual who asserts rights under applicable laws that forbid such retaliation, including, but not limited to; Title IX of the Education Amendments of 1972; the Federal and Maryland Occupational Safety and Health Acts;  False Claims Act; Affordable Care Act; Title VII of the Civil Rights Act of 1964; Equal Pay Act; Section 1981 of Civil Rights Act of 1866; Civil Rights Act of 1871; American Recovery and Reinvestment Act of 2009; Animal Welfare Act; Racketeer Influenced and Corrupt Organizations Act; Major Fraud Act; Employee Retirement Income Protection Act of 1974; Age Discrimination

in Employment Act; Americans with Disabilities Act; ADA Amendments Act of 2008; Pregnancy Discrimination Act; Family and Medical Leave Act; Fair Labor Standards Act; Fair Credit Reporting Act; Labor Management Relations Act; National Labor Relations Act; Uniformed Services Employment and Reemployment Rights Act of 1994; Safe Drinking Water Act; Sarbanes-Oxley Act of 2002; Maryland law requiring reasonable accommodation for disabilities due to pregnancy; and any and all other federal, state, local laws, and rules or regulations promulgated thereunder that prohibit Stevenson University from retaliating against those who assert rights.

The University encourages any person who in good faith believes or suspects Stevenson University’s non-compliance with any of the laws and regulations recited immediately above to report immediately his/her concerns to the President, Vice President, Dean or Director of the applicable University department, or to the confidential Ethics Hotline vis 24/7 access by phone or Internet (1-800-765-3277; www.bhsonline.com). All reports of concerns about these compliance areas will be considered confidential to the fullest extent allowed by law and to the fullest extent practicable, and will be shared with others only on a “need to know” basis. Reports may be made anonymously; however, any investigation may be hampered or impracticable if the reporting individual cannot be identified and questioned about the allegations and related facts.

The University requires the Stevenson Community to comply with any and all applicable laws that forbid retaliation against persons who exercise their legal rights thereunder. Anyone within the Stevenson Community who violates this anti-retaliation policy will be subject to disciplinary consequences, which may include, but are not necessarily limited to, termination of relationship with the Stevenson Community.

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