Whistleblower Protection Policy

I. PURPOSE

91�� is committed to the highest ethical and professional standards of conduct. To achieve this goal, the University relies on each member of the university community to transact university business in compliance with all laws, regulations and University policies related to their positions and areas of responsibility, as well as to their behavior, honesty, integrity, and good judgment.

As stated in the University’s code of conduct (section 2-Employee Conduct, ), all Rockhurst employees are encouraged to report actual or suspected violations of laws, regulations or university policies or procedures, or other suspected wrongdoings that come to their attention, including violations of ethical and professional standards(“Violations”). Supervisors have a special duty to take reasonable steps to recognize violations in their areas of responsibility.

The general purpose of this policy is to protect any Rockhurst employee or other member of the Rockhurst community who makes a good-faith disclosure of suspected Violations. This policy establishes the appropriate reporting mechanisms to be used for notification of known or suspected wrongdoing and protection from retaliation.

II. SCOPE

This policy applies to all Rockhurst employees (whether full-time, part-time, or temporary employees). This policy does not replace or supersede existing mechanisms such as (for example):

Procedures outlined for addressing employee misconduct in the Employee Handbook.
Procedures outlined for Addressing allegations of faculty misconduct in the Faculty Handbook.
Procedures outlined in the Student Code of Conduct for addressing complaints against students.
Procedures for addressing Sexual Harassment under the Sexual Harassment Policy or Discrimination/Harassment under the Non-Discrimination Policy.

III. PROCEDURES

Reporting Procedures

The following channels are available to report suspected or actual Violations:
- Report it directly to your supervisor or department head or chair. If the report involves a supervisor, report to the Human Resource office. Supervisors or other university offices receiving compliance reports should contact the Office of Compliance & Risk Management to determine next steps and should not investigate the matter themselves.
- Report it to the area-specific compliance office or to the Office of Compliance & Risk Management as follows:

Office of Compliance & Risk Management
91��
Kimberly Brant Schmelzle
Office of Compliance & Risk Management/Title IX Coordinator
Conway 102
Kimberly.brantschmelzle@rockhurst.edu
(816) 501-4036

Make a Report through the University Compliance & Ethics hotline. Where individuals are uncomfortable discussing concerns with a university official, a confidential and anonymous report can be filed through the Compliance & Ethics Hotline. Lighthouse is a third-party ethics and compliance hotline provider that collects information anonymously. Reports can be made 24 hours a day, 7 days a week. The following are ways that you can contact the University hotline:
- Website:
- Anonymous Reporting App: Keyword: Rockhurst
  - Detailed instructions
- Toll-Free Telephone:
  - English-speaking USA and Canada: 855-222-2919
  - Spanish-speaking USA and Canada: 800-216-1288
  - Spanish-speaking Mexico: 01-800-681-5340
  - French-speaking Canada: 855-725-0002
  - Contact us if you need a toll-free # for North American callers speaking languages other than English, Spanish or French
- E-mail:reports@lighthouse-services.com (must include company name with report)

Initial Assessment of Reports and Investigation

Reports should provide sufficient, precise, and relevant information concerning dates, places, persons, numbers, etc., to allow for a reasonable investigation to take place. The University will review every report to the hotline.

Departments within the University that have responsibility for receiving reports or complaints through the hotline are the following: the President, Chief Financial Officer, Human Resource Office, Office of Compliance & Risk Management, and/or External auditor for University (Report Recipients hereinafter referred to as “Ethics Officers.”). The report will be assessed by the Ethics Officers in consultation with appropriate university officials to determine whether it is actionable and whether it should be referred.

Examples of non-actionable reports include:

Reports regarding conduct over which 91�� does not have jurisdiction, such as off-campus conduct by an employee outside the scope of the employee’s university position.
Reports that do not provide enough information.
Reports of conduct that occurred more than a year prior. Note that the University may make exceptions to this general rule, depending primarily on the severity of the reported misconduct and the ability of the university to investigate it.
Reports that do not, as alleged, present significant compliance concerns.
Reports made in bad faith.

An investigation will be conducted if an initial assessment establishes that the report alleges a Violation and if it is supported by sufficiently specific information, or corroborating evidence. Other departments may become involved in investigations based on their areas of oversight responsibility or expertise. Reports that will be referred are those for which there is a dedicated policy or procedure. [See Scope of Policy, Sec. II].

The Ethics Officers will work with other senior management to ensure that prompt and appropriate corrective action is taken when and as needed, in compliance with any applicable policies. Employees will be given an opportunity to review and respond to relevant evidence prior to any disciplinary action being taken against them. Employees are required to cooperate with any investigation under this procedure.

Depending on the nature of the complaint and the findings of any investigation, the University will take appropriate action, which may include disciplinary action, up to and including termination.

IV. Good Faith Complaint

Anyone filing a complaint concerning a Violation or suspected Violation must be acting in good faith and have reasonable grounds for suspecting the information disclosed indicates a potential Violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or with the knowledge that it is false will be viewed as a serious disciplinary offense.

V. Retaliation

91�� forbids retaliation in any manner against someone who, acting in good faith, has reported a suspected Violation, assisted in making a report, cooperated in an investigation, or otherwise exercised their rights or responsibilities under this policy. An employee who feels that they have been retaliated against may file a written complaint with the Director of Compliance & Risk Management. In the event the retaliation complaint involves the Director of Compliance & Risk Management, the complaint may be filed with the Chief Financial Officer. A retaliation complaint that Rockhurst, after investigation, substantiates will result in disciplinary action up to and including termination of employment.

VI. Confidentiality

The University will assess all reported alleged Violations under this policy and will make every effort to protect the identity of the person reporting alleged Violations. Rockhurst cannot guarantee confidentiality if identification of the reporting individual is necessary to the University or law enforcement officials for the purposes of investigating the incident.

VII. Policy Questions

Questions about this policy may be directed to the Office of Compliance & Risk Management.

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91����� Whistleblower Protection Policy