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"A college administrator is expected to be more than
a financier, more than a school master. He [or she] must be in some tangible
and expressive way 'the corporate consciousness of the College.'"
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I. INTRODUCTION
It is the goal of Dartmouth College to adhere to the highest ethical
standards in all that it does. Dartmouth College expects that those who are
part of the College community, including trustees, faculty, staff and student
employees ("Dartmouth Personnel") will adhere to such standards in
their dealings with each other and with those beyond the College community.
Ethical business conduct calls for all Dartmouth Personnel to assume
responsibility for safeguarding and preserving Dartmouth's assets and resources
in the fulfillment of the College mission. Dartmouth will comply fully with all
relevant laws and all contract and grant requirements, as well as with its own
high standards of integrity and quality. Dartmouth Personnel are expected to
assume personal responsibility and accountability for understanding relevant
laws, regulations, and contract and grant requirements. In addition to
complying with specific laws or regulations that govern business activities,
standards of fairness, honesty, and respect for the rights of others will
govern Dartmouth's conduct at all times.
II. ETHICAL PRINCIPLES
A. COMPLIANCE WITH LAWS.
Dartmouth College will transact its business in compliance with the laws of
the jurisdictions in which it does business. Dartmouth Personnel will
familiarize themselves with any legal obligations arising out of the work done
for Dartmouth, including but not limited to the obligations to comply with
applicable recordkeeping requirements and not to retaliate against anyone who
reports a suspected violation of the law. If questions arise regarding
compliance with the law, or if it appears that a College policy conflicts with
the relevant law, the personnel who become aware of that situation should
contact the College office that has oversight responsibility for the policy, or
the Office of the General Counsel.
B. CONTRACTUAL AND GRANT OBLIGATIONS.
In addition to its commitment to comply with applicable laws, Dartmouth
College recognizes its contractual obligations to donors, the government,
suppliers, research sponsors, employees and others with whom it contracts.
Regardless of the source of funds, Dartmouth College will adhere to its
contractual obligations.
C. INTEGRITY AND QUALITY.
Dartmouth Personnel should recognize that Dartmouth College has earned and
must maintain a reputation for integrity and quality that goes beyond
compliance with laws, regulations and contractual obligations. Dartmouth
strives for excellence in administration as well as academics. Even the
appearance of misconduct or impropriety can cause severe damage to the
College's reputation. As such, Dartmouth Personnel must strive at all times to
maintain the highest standards of quality and integrity.
D. CONFLICT OF INTEREST.
Dartmouth Personnel should avoid situations that create or appear to create
conflicts between their personal interests and the interests of the College.
All decisions made by Dartmouth Personnel in the course of their professional
responsibilities to the College are to be made solely on the basis of their
desire to promote the best interests of the College. If an individual's
personal interests might lead an independent observer reasonably to question
whether the individual's actions or decisions on behalf of the College are
influenced by those personal interests, the individual should recuse himself or
herself from the decision making process and notify the responsible College
officials, as described in more detail in the Conflict of Interest Policy of
Dartmouth College.
Special rules concerning disclosure of conflicts relating to research are
described in the Conflict of Interest Policy. In addition, it is the College's
policy to comply in all respects with State and Federal laws concerning
conflicts of interest, including the New Hampshire Pecuniary Benefit Law, which
governs transactions between New Hampshire charitable organizations and their
trustees and officers. Further information concerning the Pecuniary Benefit Law
may be obtained from the Office of the General Counsel.
E. CONFIDENTIAL INFORMATION.
Dartmouth Personnel may have access to confidential, proprietary and private
information. Those who have access to this information may not make any
unauthorized use or disclosures of the information, either during or after
employment.
F. ANTITRUST CONSIDERATIONS.
Like other economic enterprises, colleges are subject to federal and state
antitrust laws, which are aimed at protecting competition. For this reason,
Dartmouth Personnel should avoid agreements or exchanges of information with
other colleges and universities that adversely affect economic competition
between institutions. Dartmouth personnel should never enter into agreements
with other colleges or universities regarding future tuition, fees, financial
aid, or salary levels. In addition, it is ordinarily inadvisable for Dartmouth
Personnel to disclose or exchange future plans or projections concerning these
subjects with other colleges or universities. Dartmouth personnel should not
participate in surveys concerning these matters unless the survey seeks public
information or information that is historical in nature. Dartmouth personnel
who have affiliations with other colleges and universities (e.g., on the board
of trustees of another institution) should not disclose Dartmouth's non-public
business information to the other institution, or vice versa.
G. FINANCIAL REPORTING.
All College accounts, financial reports, tax returns, expense
reimbursements, time sheets and other documents, including those submitted to
government agencies, must be accurate, clear and complete. All entries in
College books and records, including departmental accounts and individual
expense reports, must accurately reflect each transaction.
H. AUTHORITY TO CONTRACT.
All College transactions must be authorized by appropriate individuals and
conducted in accordance with applicable College procedures. Individuals who
enter into contracts on behalf of the College should confirm the extent of
their authority to do so on a regular, in most cases, annual, basis.
I. CONSEQUENCES OF VIOLATIONS OF COLLEGE POLICIES.
Each person is responsible for ensuring that his or her own conduct and the
conduct of anyone reporting to him or her fully complies with this Code and
with Dartmouth's policies. Violations may result in the taking of appropriate
disciplinary action up to and including discharge from employment. Disciplinary
action will be taken in accordance with the procedures applicable to faculty or
staff, as the case may be. Conduct representing a violation of this Code may,
in some circumstances, also subject an individual to civil or criminal charges
and penalties.
III. REPORTING OF SUSPECTED VIOLATIONS2
A. Reporting to Management - Dartmouth Personnel should report suspected
violations of applicable laws, government or College regulations, government or
industrial contract and grant requirements, or this Code. This reporting should
normally be made initially through standard management channels, beginning with
the immediate supervisor. Alternatively, employees may go to a higher level of
management and may also report suspected violations or problems to Internal
Audit, the Executive Vice President for Finance and Administration, or the
General Counsel. If a violation is reported anonymously, the College will
investigate the violation if sufficient detail is provided to allow for an
investigation.
B. Cooperation - All employees should cooperate fully in the investigation
of any misconduct.
IV. QUESTIONS ABOUT THIS CODE
Questions about this Code may be directed to the Office of the Executive
Vice President or the Office of the General Counsel.
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