All college employees have an obligation to conduct college-related business transactions without actual, potential or perceived conflicts of interest. In accordance with this policy, college employees shall at all times act in a manner that is consistent with their position and shall take all necessary precautions to avoid any actual or potential conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a college decision that may result in a direct or indirect personal gain for that employee or for his or her family member, friend, or associate as a result of that college decision. For purposes of this policy, a family member is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

Business dealings with outside firms also should not result in unusual gains for those firms and shall not result in any gains for college employees, including kickbacks, bribes, bonuses, fringe benefits, promises of employment or other windfalls designed ultimately to benefit either the outside firm, the employee(s) involved, or both.

Details and Employee Obligations

• Any employee who has any influence on transactions involving college purchases, contracts, leases, or business matters must disclose the existence of any actual or potential conflict of interest to his or her department head as soon as possible so that safeguards can be established to protect all parties.
• Specifically, any employee who is offered a gift or a series of gifts of $100 or more in value, from any individual or entity who might possibly gain from that gift, must report that gift to his/her supervisor and ultimately to the relevant PES member in order to assure that the gift does not constitute a conflict of interest.  Employees should be aware that there are certain circumstances, such as during a bidding process, that a gift of any size would represent a conflict of interest. In addition, such an employee must also refrain from further participation in the transaction until such time as the actual or potential conflict can be reviewed and resolved.

Any employee who violates this policy will be subject to disciplinary action up to and including termination.

Reports of Suspected Improper Activities

Call 704-894-1995 or visit http://whistleblower.davidson.edu

The college has provided mechanisms for reporting various types of improper behavior. In order to assure adherence to the college’s policies regarding honorable behavior in financial matters specifically, the college now provides several mechanisms to assist and encourage employees to come forward in good faith with reports or concerns about suspected violations of college policy.

Employees may report suspected non-compliance issues without fear of reprisal or retaliation. Any employee with a question about the propriety of any practice under college financial policies and procedures should seek guidance from his/her supervisor or the college official who has responsibility for overseeing compliance with the particular policy or procedure.

Any employee who becomes aware of a material violation of college financial policies should report that violation regardless of whether the employee is personally involved in the matter. That employee may request that such a report be handled as confidentially as possible under the circumstances, and the college will handle such reports with discretion and regard for the privacy of the reporting individual.

Any complaint regarding financial misconduct or inappropriate expenditure(s) of funds or any claim regarding questionable internal controls, accounting practices or auditing matters should be directed to the Vice President for Business and Finance or the President. Any employee with such a claim, who wishes to remain anonymous, may leave an anonymous message via telephone or web for the Chair of the Trustee Audit and Budget Committee or the Chair of the Board of Trustees of Davidson College. Those anonymous reports can be made by telephone by dialing 704-894-1995 or accessing the whistleblower website  (whistleblower.davidson.edu). Please sure to give as complete and detailed information as possible in order to assure appropriate follow-up to the complaint. Please understand as well that such action should be taken with great seriousness and concern about the consequences.

Questions regarding this policy should be directed to Human Resources at 704-894-2213.