Non Retaliation Policy Picture Optional Open Communication Non Retaliation Policy Brought to you by Employee Relations and Compliance Services

Objectives Compliance Awareness Survey Morehead Survey Findings Best Practices

Compliance Awareness Survey FY16 Key findings: 100% know how to locate the Hotline Number 97% are aware of UF Health Non Retaliation Policy 72% are comfortable reporting concerns to their manager

Compliance Awareness Survey A total of 3,333 employees participated and 240 provided additional comments.

What were some of the comments? Lack of trust Manager unapproachable No action is taken Fear of retaliation Nothing is confidential It will be used against you Best not to say anything Will be written up

Morehead Survey Findings

Morehead Findings A high percentage of reporters experienced retaliation. 63% Percentage of employees who observed and reported misconduct 21% Percentage of reporters who experienced retaliation Total One in Three Source: Morehead Compliance Consulting, “Reporting Retaliation and Culture” 2016

Types of Retaliation Against Reporters 69% Supervisor intentionally ignored or treated me differently 59% Other employees intentionally ignored or treated me differently 54% Supervisors or managers excluded me from decisions 49% Verbally abused by supervisor or managers 47% Not given promotions or raises 43% Verbally abused by other employees 38% Almost lost job Source: Morehead Compliance Consulting, “Reporting Retaliation and Culture” 2016

Effects of Retaliation on Employees Doubles likelihood of employees leaving the organization within two years. Decreases employee engagement. Increases likelihood that employees will make reports to the government. Source: Morehead Compliance Consulting, “Reporting Retaliation and Culture” 2016

Improving Reporting Employees are more likely to report events internally when: Employee believes that management acts ethically. Employee believes that the organization holds individuals accountable. Organization has an effective compliance program, including: Written standards Training Company provides resources and advice (communications) Anonymous and/or confidential reporting Performance evaluations on ethical conduct Systems to discipline violators

Who you Report to affects Retaliation Data shows reporting to direct managers results in less retaliation reports. 40% Who reported to Hotline experienced retaliation 27% Who reported to senior management experienced retaliation 17% Who reported to direct managers experienced retaliation Source: Morehead Compliance Consulting, “Reporting Retaliation and Culture” 2016

Best Practices Retaliation Avoidance

Retaliation Any adverse action taken against an employee as a result of a complaint. Includes demotion, discipline, firing, salary reduction, negative evaluation, change in job assignment, or change in shift assignment. Can also include hostile behaviors or attitudes. Need not be intended - Actions taken with the best of intentions may still have a negative impact on the employee.

Retaliation Facts Over the last decade, retaliation claims against employers filed with the Equal Employment Opportunity Commission (EEOC) have increased over 35%. Retaliation claims now exceed race discrimination claims for the first time in EEOC history.

Retaliation Need not be Intended Example: A female employee complains to her manager that a male co-worker is making advances towards her. In response, the manager changes the female employee’s shift from days to evenings. Even though the manager didn’t intend to hurt either employee, this action could be retaliatory if the female employee preferred the day shift. Solution: Address the problem—do not avoid it by removing the complaining employee from the situation. UF Health has policies that support addressing poor workplace behavior.

What NOT to do with Employee Complaints Fail to take complaints seriously. Promise the employee that you will keep this confidential. Delay an investigation. Not conduct a thorough investigation Fail to document the investigation in an appropriate manner. Fail to monitor your work unit to seek out potential discriminatory disparities.

Best Practices Be friendly and open to talk (open door policy). Do not immediately go into defense mode. Treat every complaint seriously. Be sincere, give the employee your undivided attention. Reiterate the fact that UF Health Shands takes these types of complaints seriously and will take prompt action to look into the matter. Don’t jump to any conclusions or say anything to indicate agreement with the employee; be neutral. Explain that you will keep the conversation as confidential as possible, but that others will need to be involved.

Best Practices (continued) Ask the complainant to put their complaint in writing. Follow through with a thorough investigation and address as soon as possible. Delay may result in other problems. If the complaint is without merit, explain so in a pleasant, low-key manner. If the complaint is sound, thank the employee for calling it to your attention so that you can resolve it. Check back with the employee after taking action in order to determine if the issue has been completely resolved to his or her satisfaction and no further retaliation has occurred.

Non Retaliation Policy CP04.001- Compliance Concern Reporting and Non-Retaliation. It is the policy of UF Health Shands to foster an environment of open communication so that Workforce Members understand their obligations to report Compliance Concerns or Wrongdoing and know that they are protected when they do so.

Thank you for your attention and collaboration!