Whistleblower Policy

Policy Description

Adelphi University (the “University”) is committed to compliance with applicable laws, rules and regulations and expects its trustees, officers, employees, students and volunteers to act in an honest, ethical and lawful manner at all times. This Whistleblower Policy (this “Policy”) sets forth the procedures established by the University for the reporting and handling of concerns regarding any action or suspected action taken by the University or any trustee, officer, employee, student or volunteer of the University on its behalf that is or may be illegal, fraudulent or in violation of any University policy, as well as any other matter that could cause serious damage to the University’s reputation, including a trustee, officer or employee’s involvement (or suspected involvement) in any activity, behavior or incident that is illegal or violates high business or personal ethical standards (each, a “Concern”), and prohibits retaliation against any trustee, officer, employee, student or volunteer who reports a Concern (a “Whistleblower”) in good faith. The University investigates all reported Concerns promptly, fairly, and in accordance with this policy.

Reason for Policy

The objective of this Whistleblower Policy is to encourage and enable trustees, officers, employees, students and volunteers, without fear of retaliation, to raise Concerns on a confidential and, if desired, anonymous basis so that the University can address and correct inappropriate conduct and actions.

Who Is Governed by this Policy

This policy applies to any Adelphi University trustee, officer, faculty, staff, former faculty and staff, independent contractor, agent, student and volunteer of the University.

Policy

The University encourages good-faith reporting of activity suspected of being illegal, fraudulent, or in violation of governmental regulations or University policy, or which could cause serious damage to the University’s reputation. Reports will be fully investigated by the University.

Policies to which whistleblower protection applies include:

• Policies designed to prevent financial improprieties, such as accounting policies
• Policies prohibiting fraud, theft, embezzlement, bribery, kickbacks, and abuse of University assets
• Conflict of interest policies
• Policies that address unethical conduct

This policy is not intended as a vehicle for reporting violations of the University’s applicable human resources policies, problems with co-workers or managers, or for reporting issues related to alleged employment discrimination or sexual or any other form of unlawful harassment or discrimination, all of which should be dealt with as set forth in accordance with the applicable University policies.

See related resources.

No Retaliation

Individuals, who in good faith, report activity suspected of being fraudulent, illegal, or in violation of governmental regulations or University policy, or which could cause serious damage to the University’s reputation, will not be subject to retaliation, intimidation, harassment, adverse employment action by the University, reporting (or threatening to report) to U.S. immigration authorities or other government bodies regarding the suspected citizenship or immigration status of a Whistleblower or a family or household member of a Whistleblower, or other negative consequences. For the purpose of this policy, an adverse employment action includes failure to promote, adverse impact on compensation, termination, discharge, suspension, demotion, other change in responsibilities, whether formal or informal, actions that would affect the current or future employment of a former employee or independent contractor, or other negative consequences.

If a Whistleblower believes he/she has been retaliated against, he or she should immediately go to EthicsPoint. Make a report online or report by phone, please call 855.375.6802. Reports will be kept confidential to the extent possible. EthicsPoint offers the option to submit a report anonymously.

Individuals who engage in retaliatory actions against Whistleblowers will be subject to discipline, up to and including separation from the University.

A Whistleblower is not necessarily granted immunity from consequences that are a result of participating or being complicit in the violation or suspected violation that is the subject of the report. Individuals may be the subject of discipline or an adverse personnel action for reasons unrelated to the making of a report. Notwithstanding anything contained herein to the contrary, this Whistleblower Policy is not an employment contract and does not modify the employment relationship between Adelphi University and its employees, nor does it change the fact that employees of Adelphi University are employees at will. Nothing contained in this Policy is intended to provide any person with additional rights or causes of action, other than those provided by law.

Acting in Good Faith

Anyone filing a report about a Concern must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or with knowledge that the allegation is false will be viewed as a serious disciplinary offense.

Confidentiality

Concerns may be submitted on a confidential basis by the complainant or may be submitted anonymously to EthicsPoint, the University’s third party hotline provider, and managed by NAVEX Global. Reports of Concerns will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. The University is under no obligation to investigate vague anonymous complaints that do not provide adequate information on which to base an investigation.

Procedures

A member of the Adelphi University community who has a good faith suspicion of a violation of law or Adelphi University policy is encouraged to report the concern promptly to his or her supervisor or a Human Resource representative (humanresources@adelphi.edu), who shall report such suspicion to the appropriate department. Any member of the University who is uncomfortable reporting suspected violations may report the concern to our confidential third party, EthicsPoint. Make a report online or report by phone, please call 855.375.6802.

A supervisor or Human Resources representative who merely submits a report on behalf of an employee through EthicsPoint will not separately be considered a whistleblower; rather, they are fulfilling a reporting obligation under the policy. However, if when submitting the report, the supervisor or Human Resources representative adds their own, independent concerns based on their knowledge and observations, then the supervisor or Human Resources representative is also a whistleblower.

Nonetheless, even where the supervisor or Human Resources representative is not deemed a whistleblower, they will be afforded the anti-retaliation protections as set forth in this policy.

Confidential Reporting Hotline

Whistleblower complaints reported via the EthicsPoint reporting hotline will be handled with sensitivity, discretion and confidentiality to the extent allowed by the circumstances and the law. Generally, this means that whistleblower complaints will only be shared with those who have a need to know so that an effective investigation can be conducted and a determination made as to what action to take based on the results of any such investigation; and, in appropriate cases, with governmental and/or law enforcement personnel. Should disciplinary or legal action be taken against a person or persons as a result of a whistleblower complaint, such persons may have a right to know the identity of the whistleblower and records and information maintained by the University and the whistleblower may be subject to disclosure.

A supervisor or a Human Resource representative (humanresources@adelphi.edu) should promptly make a report to EthicsPoint if he or she receives a complaint relating to:

• Financial improprieties, such as accounting policies
• Fraud, theft, embezzlement, bribery, kickbacks, and abuse of University assets
• Noncompliance with the University’s Conflict of interest policies
• Other unethical conduct

The Adelphi University Audit Committee is designated as the compliance contact with respect to this policy, and the Audit Committee Chair will receive reports of Concerns. The person who submitted a complaint will receive a response acknowledging receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. Individual(s) performing services for the area related to the reported matter shall immediately recuse him/herself from the investigation and inform the Chair of the Audit Committee of the Board of Trustees immediately in writing at trustees@adelphi.edu. The Audit Committee may investigate the reported suspicion or appoint impartial attorneys or outside auditors to complete the investigation.

The University shall report to the Audit Committee annually at regular meetings of the Audit Committee on all compliance activity with respect to this Whistleblower Policy.

The Audit Committee shall address all reported suspicions regarding corporate accounting practices, internal controls, auditing, fraud, embezzlement, or other illegal activities (“Accounting Concerns”). The University shall promptly notify the Audit Committee Chair of any Accounting Concern and shall work with the Audit Committee until its resolution. Promptly upon receipt, the Audit Committee shall evaluate whether a reported suspicion constitutes an Accounting Concern and, if so, shall promptly determine what professional assistance, if any, is needed by the University in order to conduct an investigation. The Audit Committee will be free in its sole discretion to engage outside auditors, counsel or other experts to assist in the investigation and in the analysis of results.

The person who is the subject of a Whistleblower complaint should not be present at or participate in Board or committee deliberations or vote on the matter relating to such complaint, provided that nothing in this subparagraph prohibits the board or committee from requesting that the person who is subject to the complaint present information as background or answer questions at a committee or Board meeting prior to the commencement of deliberations or voting relating thereto.

Records

The University will retain on a strictly confidential basis for a period of seven years (or otherwise as required under the University’s record retention policies in effect from time to time) all records relating to each report received of a violation or suspected violation of a law or University policy. Such records shall include

• (i) the nature of the Concern (including any specific allegations made and the persons involved);
• (ii) the date of receipt of the Concern;
• (iii) the current status of any investigation into the Concern and information about such investigation (including the steps taken in the investigation, any factual findings, and the recommendations for corrective action);
• and (iv) any final resolution of the Concern.

All such records are confidential and such records will be considered privileged and confidential.

Distribution

A copy of this Policy will be distributed to each trustee, officer, employee, student and volunteer promptly following the adoption of or any amendments to this Policy, and at such time as a person becomes a trustee, officer, employee, student or volunteer. This distribution requirement may be satisfied by posting a copy of this Policy on the Organization’s website or at the Organization’s offices in a conspicuous location accessible to employees and volunteers.

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Resources

Report concern or suspicious activity regarding Financial improprieties, such as accounting policies, fraud, kickbacks, bribery, embezzlement, unethical conduct and/or noncompliance with the University’s Conflict of Interest policies: report confidential concerns to or report concerns anonymously via our third party, EthicsPoint confidential reporting hotline.

The Office of Community Concerns and Resolution provides members of the Adelphi community with a single office for community members to file a non-emergency complaint or concern, including those that involve harassment, discrimination or sexual misconduct and to provide oversight of the many channels for issue resolution at Adelphi.

For non-emergency concern or complaint regarding harassment, discrimination or sexual misconduct or to provide oversight of the many channels for issue resolution, please contact the Office of Community Concerns and Resolution by email at occr@adelphi.edu or by phone at 516.877.6864 and leave a message. Messages will be responded to within the next business day.

For Emergency concerns or complaints, please contact Public Safety at 516.877.3511 or call 911. Please refer to their webpage for further information.

Document History

• Last Reviewed Date: December 13, 2025
• Last Revised Date: December 13, 2025
• Policy Origination Date: July 01, 2015

Who Approved This Policy

Policy Owner and Board of Trustees