Moravian College
Confidential Disclosure Policy


Applicability: All trustees, faculty and employees of the College, including officers and staff.

Purpose: Define subject matter and confidential reporting procedures for the reporting of any questionable financial activities without fear of retaliation.

Policy Scope: This Policy applies to any questionable financial, accounting, financially-related internal control or auditing matters, or any indications of possible financial fraud.

Reporting: This policy assumes the individual with any knowledge of questionable financial activity has a responsibility to communicate such activity forward. Any person wishing to raise a questionable matter should first discuss the matter with their immediate supervisor. The College will protect the “reporting person” from any retaliatory action from the supervisor should it arise. Either the "reporting person" or the supervisor is required to report the matter in accordance with the procedure described below.

If the "reporting person" believes it would be inappropriate to discuss the matter with their supervisor, or is not satisfied after discussion with their supervisor, the matter should be reported in accordance with the following procedure.

Reports, either signed or anonymous, involving any of the matters which are subjected to this Policy, should be sent to the College President. Reports should be in writing, marked "Confidential" and should contain details of the matter under question. .

Upon receipt of any such reports, the College President will report the matter to the Chairman of the Finance Committee of the Board of Trustees, and advise the Chair of the Board of Trustees as appropriate.

Confidentiality and Prohibition of Retaliation: Information related to any reported matters and details of any investigations will be kept confidential to the maximum extent possible, consistent with the need to conduct an investigation and correct any matters or procedures.

Retaliation of any kind against any personnel involved in reporting or investigating any matters is forbidden and any person engaging in retaliation is subject to disciplinary action

effective 3/5/2007