2.35 Ethics and Integrity Policy
Ithaca College is committed to protecting its resources and complying with all applicable international, federal, state and municipal laws, rules and/or regulations (collectively, “Laws”) and College policies. The College’s internal controls and operating procedures are intended to detect, prevent or deter improper activities. However, even the best systems of control cannot provide absolute safeguards against irregularities. This Ethics and Integrity Policy is intended to enable employees and others to raise questions or concerns regarding suspected fraudulent activities, or violations of Laws and/or policies of the College, within the College setting rather than seeking resolution outside the College.
2.35.2 General Responsibility
Ithaca College requires board members, officers, employees and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities to the College. As representatives of the College, we must practice honesty and integrity in fulfilling our responsibilities. It is the responsibility of all board members, officers, employees and volunteers to refrain from fraudulent activity in the course of their work for the College, and to comply with all Laws and policies of the College.
2.35.3 Procedures for Reporting Violations
The vice president and general counsel shall be responsible for the general administration of this policy, and in that capacity shall have direct access to the audit committee of the board of trustees and be required to report to the audit committee at least annually on the operation of the policy.
The College encourages that employees share their questions and concerns regarding what they believe to be a violation of Laws or policies of the College with someone at the College who can address them appropriately. In most cases, an employee’s supervisor is in the best position to address a question or an area of concern. However, if an employee is not comfortable speaking with a supervisor or is not satisfied with a supervisor’s response, the employee is encouraged to speak with the Human Resources Department or anyone in management whom the employee is comfortable in approaching. Supervisors and managers are required to report suspected violations of Laws or College policy to the vice president in charge of their respective unit, who has responsibility to investigate all reported violations; provided, however, that (a) in the event of an alleged violation involving the applicable vice president, the supervisor or manager shall instead report the matter to the President, and (b) in the event of an alleged violation involving the President, the supervisor or manager shall instead report the matter to the Chair of the board of trustees.
If an individual is not satisfied or comfortable with raising questions or concerns internally, or if the reporting individual is not a College employee, the individual may contact EthicsPoint. The vice president and general counsel is responsible for receiving all questions and concerns filed with EthicsPoint and investigating and resolving all reported violations of Laws and/or policies of the College. The vice president and general counsel has direct access to the audit committee of the board of trustees for such purposes. In the event that a reported violation filed with EthicsPoint involves the vice president and general counsel, EthicsPoint shall forward the report directly to the President and the Chair of the board of trustees, who shall refer the matter to the audit committee as appropriate.
All reports will be promptly investigated to the extent reasonably possible. If warranted by the investigation, appropriate corrective action will be taken in accordance with applicable Laws and/or College policies.
2.35.4 Accounting and Auditing Matters
The audit committee of the board of trustees shall address all reported questions or concerns regarding the College’s financial practices, internal controls or auditing. Such questions or concerns should be submitted to the vice president and general counsel (either directly or through EthicsPoint as described above), who shall immediately notify the chair of the audit committee and work with the committee until the matter is resolved. In the event a question or concern with respect to the College’s financial practices, internal controls or auditing involves the vice president and general counsel such that the person submitting the question or concern is not comfortable submitting it to the vice president and general counsel, the question or concern may instead be submitted to the President or through EthicsPoint as described above.
2.35.5 Acting in Good Faith
Anyone raising a question or concern pursuant to this policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of Laws or policies of the College. Persons making allegations that are malicious or are knowingly false and can not to be substantiated may be subject to disciplinary action up to and including dismissal.
Reports within the scope of this policy may be submitted on a confidential basis or may be submitted anonymously. The identity of persons reporting questions or concerns that are not submitted anonymously, but for which confidentiality is requested, will be disclosed only when necessary or advisable to investigate the report or for related matters, or when required by law. Although the College endeavors to investigate all reports, including anonymous reports, the nature of anonymous reports makes investigation, determination, and remediation more difficult and, at times, impossible.
Accordingly, in the event of an anonymous report, the College reserves the right to determine if there is sufficient detail to conduct an investigation.
2.35.7 No Retaliation
No board member, officer, employee or volunteer shall suffer intimidation, harassment, discrimination, retaliation or adverse employment consequence as a result of making a good faith report of suspected fraudulent activity or a suspected violation of applicable Laws or policies of the College, or for cooperating in the investigation of such a report. An employee who retaliates against someone who has made such a good faith report and/or or cooperated in the investigation of such a report is subject to discipline up to and including termination of employment.
Last updated: September 28, 2015