1. Non Retaliation Policy
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Open Communication
Non Retaliation Policy
Brought to you by Employee Relations and Compliance Services

2. Objectives Compliance Awareness Survey Morehead Survey Findings
Best Practices

3. 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

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

5. 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

6. Morehead Survey Findings

7. 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

8. 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

9. 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

10. 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

11. 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

12. Best Practices Retaliation Avoidance

13. 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.

14. 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.

15. 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.

16. 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.

17. 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.

18. 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.

19. Non Retaliation Policy
CP 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.

20. Thank you for your attention and collaboration!