The University’s Institutional Code of Ethics is aimed at helping us respect laws and regulations and guide our actions in decision making. The Whistleblower Protection Policy supports the Institutional Code of Ethics in addressing issues and concerns that may arise. Policy Statement The University Whistleblower Protection Policy provides a means by which a complainant may, in good faith, report issues or concerns in connection with violation of a law, rule or regulation promulgated pursuant to law. The University will act in a fair manner with respect to any individual named in a complaint, the serious nature of the complaint, the credibility of the information or allegations found in the complaint and the prospect of effective resolution of the complaint. Nature of the Complaint In accordance with the New Jersey Conscientious Employee Protection Act, the University has adopted the following procedures to facilitate the submission of information on a confidential and anonymous basis regarding the following issues: Accounting and internal controls or audit matters, Actual or potential violations of laws, rules or regulations Other suspected wrongdoing, including violation of the University’s Institutional Code of Ethics. Protection of Complainants The policy offers protection from retaliation to the complainant regarding matters that are, or could result in violations, of law, rule or regulation promulgated pursuant to law, provided that the complaint is made: In good faith, in a manner consistent with the values of the University and with respect to others; In the belief of the complainant that the conduct or matter addressed by the complaint constitutes a serious violation. No complaint that satisfies the above conditions shall result in retaliation or threat against the complainant. The University and its Board of Trustees, officers, employees and agents shall not penalize, discharge, demote, suspend, threaten, harass, transfer to another undesirable assignment or discriminate against the complainant for reporting attention to a suspected or unethical act. Any act of retaliation shall be treated by the University as a serious violation of policy which could result in disciplinary action. This protection extends to an individual who provides information in relation to an investigation, including an internal investigation. Confidentiality The University will treat all complaints as confidential and privileged to that extent possible. The complainant is encouraged to provide his/her name on the complaint, but may also make the complaint anonymously. Making the Complaint Complaints made under this policy must be submitted to the Director of Internal Audit, through the following methods of communication: By telephone: 973-720-3108 In writing: William Paterson University College Hall - Rm 155 Wayne, N.J. 07474-0913 Attention: Director of Internal Audit (Strictly Confidential) By e-mail: firstname.lastname@example.org The complaint should provide sufficient, precise and relevant information concerning dates, places, persons, numbers etc., such as to allow for a reasonable investigation to take place. The Director of Internal Audit will determine whether the complaint is covered under this policy. Investigation If the Director of Internal Audit determines that the complaint is covered by this policy, he/she will conduct an investigation and may enlist legal counsel, accounting, human resources or other advisors as are appropriate. The Director of Internal Audit shall have access, during an investigation, to all records of the University. Full compliance with an investigation will be required. The Director of Internal Audit will take all reasonable efforts to protect the confidentiality of the complainant. Investigations will be conducted as quickly as possible, based on the nature and complexity of the complaint and the issues raised. The Director of Internal Audit shall retain record of all complaints for seven years. Reporting to the Finance and Audit Committee On a quarterly basis, the Director of Internal Audit will report to the Finance and Audit Committee of the Board of Trustees, the number, nature and outcome of complaints received and investigated under the policy. The Director of Internal Audit will promptly report to the Finance and Audit Committee any complaint of material consequence.