To further its mission of producing, in a humanistic tradition, health care professionals and biomedical knowledge that will enhance and extend the quality of life in our communities, Western University of Health Sciences is committed to the principle that all of its affairs be conducted in compliance with applicable laws and the University’s own policies. Employees and other individuals representing the University are expected at all times to act in conformity with this principle.
It is University policy to receive, evaluate and, where the information provided reasonably permits, investigate any allegation that an individual affiliated with the University has engaged in Improper Conduct as defined in the policy. The University encourages individuals, acting in good faith, to report suspected Improper Conduct to the University.
Conduct Covered by the Policy
Improper Conduct is defined as any action or activity by an employee that is undertaken in the performance of the employee’s official duties or with the appearance or representation that it is undertaken in the performance of official duties, whether or not the action or activity is within the scope of his or her employment, and that is:
- in violation of any federal or state law or regulation, including, but not limited to, corruption, malfeasance, bribery, theft, fraudulent claims, fraud, coercion, or conversion;
- a misuse or misappropriation of University property or willful omission to perform a duty or intentional violation of a University policy;
- economically wasteful or involves gross misconduct, incompetence or inefficiency or creates for the University potential exposure to liability and financial irregularities;
- an action or activity that is the result of a criminal act;
- a significant threat to the health or safety of members of the University community;
- an unauthorized invasion, alteration or manipulation of records and computer files;
- in pursuit of a benefit or advantage in violation of the University’s conflict of interest policy; or
- interference with a University investigation conducted in accordance with this policy, including the withholding, destruction or tampering with evidence or any effort to influence, coerce, intimidate or retaliate against an individual who has reported suspected Improper Conduct or witnesses.
The Compliance Officer has oversight responsibility for investigations of suspected Improper Conduct, and reports directly to Board of Trustees and the senior administrative officials of the University. The Board of Trustees has designated the University’s General Counsel to serve as the Compliance Officer:
Keith A. Johnson
Western University of Health Sciences
P.O. Box 1854
Pomona, California 91769-1854
Telephone: (909) 469-5465
Facsimile: (909) 498-8331
Reporting Suspected Improper Conduct
Any person may report suspected Improper Conduct as follows:
- Employees of the University are encouraged to report allegations of Improper Conduct to their immediate supervisor or to an appropriate administrator or supervisor within the operating unit.
- Any person may report suspected Improper Conduct to the Compliance Officer.
- Any person may report suspected Improper Conduct anonymously by completing a Report of Suspected Improper Conduct [Click on link at bottom of page]
The University encourages that reports be made in writing so that there is a clear understanding of the issues raised. However, oral reports may be made. Reports should focus on facts and avoid speculation or the drawing of conclusions. Reports should include as much specific information as possible.
The act of submitting a report of suspected Improper Conduct is a representation to the University that the report is made in good faith. Any individual who makes a report in bad faith, or who has reason to know that the claim is false or materially inaccurate, may be subject to disciplinary action by the University.
A report of suspected Improper Conduct should be made as soon as possible and, in all events, no later than one (1) year from the event(s) giving rise to the allegation, unless there is good cause for the delay.
The University endeavors, to the extent possible, and within the limitations of law and policy, and the need to conduct a competent investigation, to maintain confidentiality. However, all persons making a report should understand that it is possible that their identity may become apparent during the course of the University’s investigation. If a person making a report self-discloses their identity, the University is no longer obligated to maintain confidentiality of that person’s identity.
Protection Against Retaliation
The University prohibits any retaliation against an individual who, in good faith, reports suspected Improper Conduct in any manner with the intent of adversely affecting the terms or conditions of employment of that individual.
Roles, Rights and Responsibilities of Persons Who Report Suspected Improper Conduct
An individual who reports suspected Improper Conduct to the University:
- Provides the initial information related to a good faith belief that there was Improper Conduct
- Shall not obtain evidence to which he or she does not have a right of access
- Must be truthful and cooperative with the Compliance Officer, investigators and others to whom he or she makes a report
- Has the right to be informed of the disposition of his or her disclosure.