Purpose of the Policy
New York University (“University”) is committed to complying with all applicable laws and regulations, accounting standards, accounting controls and audit practices. Any employee of the University may submit a good faith complaint regarding compliance matters to the management of the University without dismissal or retaliation of any kind. To facilitate the reporting of employee complaints, the University has established the following procedures for (1) the receipt, retention and treatment of complaints regarding compliance matters, and (2) the confidential, anonymous submission by employees of concerns regarding compliance matters. The University’s Audit Committee will oversee the handling of employee complaints.
This policy is one, but not the only, avenue for addressing complaints or concerns among members of the University community. Other such avenues include, for example, the Human Resources Division, the Office for Equal Opportunity, and mechanisms outlined in the University’s Student guides for addressing student complaints as diverse as anti-harassment complaints and student record privacy (See http://www.nyu.edu/life/student-life/student-communitystandards.html), as well as procedures set forth in the Faculty Handbook. Members of the University should consult the University’s web site http://www.nyu.edu/about/policies-guidelines-compliance.html for more information).
Compliance Complaint Matters
Compliance complaint matters include complaints regarding accounting, internal accounting controls, auditing matters, ethics, laws, regulations, University policies, and best business practices applicable to the University. Examples of compliance matters include, without limitation, the following:
- conflicts of interest,
- financial and business integrity issues,
- misuse of University property or assets,
- wage claims,
- research related issues,
- or other compliance and risk matters.
University Compliance Steering Committee
The University Compliance Steering Committee consists of the Provost, Executive Vice President, Executive Vice President for Health, Executive Vice President Finance and Budget, Senior Vice President and General Counsel, Senior Vice Provost for Research, and Deputy President. (See http://www.nyu.edu/about/policies-guidelines-compliance/compliance/UCSCCharter.html )
Receipt of Employee Complaints
Employees with concerns regarding compliance matters should, in the first instance, attempt to resolve their concerns with their immediate supervisors and within their own business unit. Where employees cannot resolve concerns within their academic or administrative units, they may report their concerns to Internal Audit, the Office of General Counsel, a subject matter expert member of the Compliance Officers / Risk Management Working Group (See http://www.nyu.edu/about/policies-guidelines-compliance/compliance/compliance-officers-contacts.html), the University Chief Compliance Officer or the NYU in Abu Dhabi Chief Compliance Officer in the Office of Compliance and Risk Management.
Employees also may forward complaints on a confidential or anonymous basis through the Compliance and Risk Reporting telephone or website (See http://www.nyu.edu/about/policies-guidelines compliance/compliance/compliance-reportingline.html), e-mail or regular mail, to the attention of the University Chief Compliance Officer. (For a complete description of the University’s Compliance Program and Officers see http://www.nyu.edu/about/policies-guidelines-compliance/compliance.html )
Reports of alleged sexual, disability, or discriminatory harassment should be directed to the Office of Equal Opportunity at 212-998-2375 or one of the contacts listed at http://www.nyu.edu/about/policies-guidelines-compliance/equal-opportunity/harassment-and-discrimination/anti-harassment-contacts-list.html
Treatment of Complaints
Upon receipt of a complaint, the Office of Compliance and Risk Management will: (i) determine whether the complaint pertains to compliance matters, and (ii) acknowledge receipt of the complaint to the sender.
Complaints relating to compliance matters will be reviewed under the Compliance Officer’s direction and oversight by the University Compliance Steering Committee, General Counsel, Internal Audit, or such other persons as the Audit Committee determines to be appropriate. The Compliance Officer will use his or her "best efforts" to investigate every complaint. The resources expended will depend upon: (1) the nature and severity of the allegation; and (2) the sufficiency and apparent validity of the information provided
Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review. Prompt and appropriate corrective action will be taken as warranted by the University. The Compliance Officer shall provide compliance oversight of any corrective action.
The University will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding compliance matters.
Reporting and Retention of Records of Complaints and Investigations
The Office of Compliance and Risk Management will maintain a log of all complaints, tracking their receipt, investigation, and resolution and shall prepare a periodic summary report thereof for the University Compliance Steering Committee and the Audit Committee. Copies of complaints and such log will be maintained in accordance with the University’s document retention policy.