Sarah Lawrence College trustees, officers, employees, and volunteers (Person) are expected to observe high standards of professional ethics in the conduct of their duties and responsibilities. Maintaining ethical standards, including appropriate accounting, internal controls, auditing, and compliance with all federal, state and local laws, is the responsibility of each member of the Sarah Lawrence College community. The college believes that early identification and resolution of inappropriate conduct and actions are critical to maintaining laws or regulations that govern the college’s operations.

This policy provides guidance for how a Person may raise concerns regarding suspected dishonesty, fraud, or misconduct on a confidential or, if desired, an anonymous basis. It is the responsibility of all Persons to report in good faith any concerns they may have regarding actual or suspected activities that may be illegal or may violate the college’s policies.

Examples of such activities may include:

  • Billing fraud, expense account abuse, kickbacks or forgery
  • Improprieties in the approval, management, administration or assignment of contracts
  • Embezzlement, theft, or misappropriation of funds, supplies, equipment, goods or any other asset
  • Authorizing or making payment for goods not delivered or services not performed
  • Authorizing or receiving payments for hours not worked
  • Receiving tangible personal benefit from a third party as a direct consequence of performance of duties as a college employee
  • Inappropriate use or distribution of college resources
  • Pursuing or obtaining a benefit in violation of the college’s Conflict of Interest Policy
  • Illegal activities involving the wrongful use, disclosure, or appropriation of an individual’s personal information, such as identity theft, disclosure of a student’s education records in violation of FERPA, or misuse of personal financial or other private information
  • Other activities that violate the law

Reporting of Misconduct

Any Person who observes activities or other practices they believe to be against the law or college policy should report these activities in the first instance to the Vice President of Finance and Operations. If the suspected improper or illegal activity involves by the Vice President of Finance and Operations, then the incident should be reported to the President of the college while incidents involving the President of the college or the Chair of the Audit Committee should be reported directly to the Chair of the Board of Trustees.

Alternatively, Persons may submit concerns confidentially and anonymously via the Whistleblower Service at or by phone at 833-340-0007 (English) or 800-216-1288 (Spanish).

Reporting and Investigation Procedures               

Whenever a case of possible improper or illegal behavior is reported, the individual receiving the report, as noted above, shall prepare a written record of the complaint. The investigation will be carried out confidentially with assistance from the Secretary to the Board and/or the college’s Director of Human Resources, as appropriate.

Upon completion of the investigation, the college will take appropriate action commensurate with the investigative findings. The disposition of the investigation will be reported to the President and/or the Audit Committee of the Board of Trustees, as appropriate.

The college will maintain appropriate confidentiality throughout the investigatory phase and for as long as possible and all reported information will be kept confidential to the extent possible.

Protection of Whistleblowers from Retaliation The college will not permit any negative or adverse actions to be taken again any Person who in good faith reports, or assists in the investigation of, an act included within this policy, even if such report is mistaken.

Distribution of Policy A copy of this policy will be distributed to all trustees, officers and employees at least once per year.