Claremont McKenna College is committed to the highest standards of financial conduct. This policy is designed to enable all of the College's faculty and staff to report concerns about possible financial misconduct, with reassurance that they will be protected from retaliation for acting in good faith. Reports on financial misconduct would address such issues as accounting discrepancies, fraud, accounting misrepresentations, auditing matters, accounting omissions, misappropriation of grant funds, kickbacks, theft of college assets or use of such assets for personal benefit, and falsification of time records.
All reports of suspected financial misconduct by Claremont McKenna College employees or trustees shall be made confidentially and directly to the Chair of the Audit Committee of the Board of Trustees through the College's registered in-house counsel, who shall oversee the receipt, retention and resolution of such reports. The Chair of the Audit Committee will work with the registered in-house counsel, the Administration and outside advisors to ensure that these reports receive the appropriate attention. Any employee ultimately found to have engaged in financial misconduct is subject to disciplinary action by the College, which may include dismissal as well as prosecution by appropriate law enforcement authorities.
The protection of employees who submit reports of suspected financial misconduct is an important part of this policy, as is maintenance of the confidentiality, objectivity and independence necessary to resolve complaints appropriately. The Chair of the Audit Committee, the registered in-house counsel and the Administration share responsibility for maintaining these features of the policy, although, depending on the nature of the discipline or the actions of law enforcement agencies, this confidentiality cannot be guaranteed.
It is a violation of this policy to knowingly make fraudulent allegations of financial misconduct with the intent to cause harm to another individual. Those making such allegations are also subject to disciplinary action, up to and including termination.
Since confidentiality is an important part of this policy, the College has contracted with an outside reporting service called Convercent to facilitate the transmission of reports of financial misconduct to the registered in-house counsel and the Chair of the Audit Committee of the Board of Trustees. This is part of the program CMCListens; more information is available on the CMCListens page.
Audit Committee Reports
The College's registered in-house counsel, working in conjunction with Convercent, shall prepare periodic summaries of complaints received by categories of complaints, including accounting, internal accounting controls, or auditing matters for review by the Audit Committee. As appropriate, reports regarding the status of specific complaints may be reported on a more frequent basis.
The Audit Committee shall evaluate annually the effectiveness of these guidelines and recommend and adopt changes as necessary.
Any questions regarding this policy should be directed to the registered in-house counsel or the Director of Human Resources.