Whistleblower Policy

This policy applies to all Earlham College employees, trustees, student employees, volunteers, contractors, consultants, vendors, and others acting on behalf of or conducting business with Earlham College or any of its departments or operating units, including the Earlham School of Religion.

Earlham College is committed to conducting its affairs in an ethical, honest, and lawful manner and expects members of the College community to conduct themselves in accordance with applicable laws, regulations, and College policies.

The purpose of this policy is to encourage the reporting of suspected or actual misconduct, establish protections for individuals who make good-faith reports or participate in investigations, and support the College’s commitment to integrity, accountability, and compliance.

The College encourages individuals to report in good faith suspected violations of law, fraud, financial improprieties, misuse of College resources, significant violations of College policy, conflicts of interest, research misconduct, threats to health or safety, and other serious misconduct that may materially harm the College, its operations, finances, reputation, or community.

This policy is not intended to address routine workplace disagreements, personnel decisions, performance evaluations, academic judgments, student conduct matters, or other concerns that are more appropriately addressed through established College policies and procedures, unless such matters also involve conduct covered by this policy.

A report is made in good faith when the reporting individual reasonably believes the reported conduct may constitute misconduct covered by this policy.

No person shall prevent, discourage, or interfere with the good-faith reporting of concerns under this policy. No individual who makes a good-faith report or participates in the review or investigation of a report shall be subject to retaliation, harassment, intimidation, or other adverse action as a result of such participation.

Retaliation against an individual for making a good-faith report or assisting in an investigation constitutes a violation of College policy and may result in disciplinary action.

A report made in good faith shall not be considered improper solely because an investigation concludes that no violation occurred or because the reported conduct cannot be substantiated.

Individuals who knowingly make false allegations or intentionally misuse this policy may be subject to disciplinary action.

Concerns may be reported to a supervisor, department chair, dean, vice president, the Director of Human Resources at [email protected], the President at [email protected], the Chair of the Audit, Risk Management and Compliance Committee of the Board of Trustees at [email protected], or anonymously through Earlham’s Whistleblower Report Form.

Reports received under this policy shall be reviewed by the College official to whom the report is made or by another appropriate College official designated by the President. Reports involving the President, a Vice President, or another senior administrator shall be referred to the Chair of the Audit, Risk Management and Compliance Committee of the Board of Trustees. Reports involving the Chair of the Audit, Risk Management and Compliance Committee shall be referred to the Chair of the Board of Trustees or another trustee designated by the Board.

The College shall conduct or authorize an investigation of reports that, on their face, present credible allegations of misconduct covered by this policy. Investigations shall be conducted by individuals who are not implicated in the reported conduct and who do not have a conflict of interest with respect to the matter under review. The College may utilize Human Resources personnel, administrative officers, legal counsel, auditors, or other qualified internal or external investigators as appropriate to the circumstances.

Individuals subject to this policy are expected to cooperate fully with authorized investigations.

When an investigation substantiates misconduct, the College may take corrective action, including changes to practices or procedures, disciplinary action, referral to another College process, restitution, or referral to governmental or regulatory authorities when warranted.

The College will make reasonable efforts to maintain the confidentiality of reports and investigations consistent with applicable law, the need to conduct a fair and thorough review, and the rights of all persons involved.

The Audit, Risk Management and Compliance Committee of the Board of Trustees shall oversee this policy and shall receive periodic reports regarding matters arising under it, consistent with the protection of confidential information and the integrity of investigations.

This policy shall be reviewed periodically by the Audit, Risk Management and Compliance Committee of the Board of Trustees. Substantive amendments to the policy shall be approved by the Board of Trustees.

• October 16, 2026: Revisions approved by the Board of Trustees upon the recommendation of the Audit, Risk Management and Compliance Committee of the Board. 
  • Broadened scope, enhanced reporting options, stronger anti-retaliation protections, formalized investigation and oversight provisions, and updated confidentiality language
• June 5, 2009: Adopted with approval of the Board of Trustees