This policy governs both the reporting and investigation of allegations of suspected unlawful activities and the protection of whistleblowers from retaliation.  It describes the procedures for investigating known or suspected improper activities and addressing complaints of retaliation for raising such issues.


Occidental College has a responsibility for the stewardship of College resources and the public and private support that enables it to pursue its mission. The College’s internal controls and operating procedures are intended to detect and to prevent or deter improper activities. However, intentional and unintentional violations of laws, regulations, policies and procedures may occur and may constitute unlawful activities. The College has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities, and to protect those employees who, in good faith, report these activities to the appropriate authority.

A College employee may not: (1) retaliate against an employee or applicant for employment who has made a protected disclosure or who has refused to obey an illegal order, nor (2) directly or indirectly use or attempt to use the official authority or influence of his or her position for the purpose of interfering with the right of an applicant or an employee to make a protected disclosure to the College. It is the intention of the College to take whatever action may be needed to prevent and correct activities that violate this policy.


A. Filing a Report of Suspected Improper Activities

  1. Any person may report allegations of suspected illegal activities. Knowledge or suspicion of improper governmental activities may originate from academic personnel, staff or administrators carrying out their assigned duties, internal or external auditors, law enforcement, regulatory agencies, and customers, vendors, students or other third parties. Allegations of suspected improper activities may also be reported anonymously.
  2. Allegations of suspected improper activities should be made in writing so as to assure a clear understanding of the issues raised, but may be made orally. Such reports should be factual and contain as much specific information as possible
  3. Normally, a report by a College employee of allegations of a suspected improper activity should be made to the reporting employee’s immediate supervisor or other appropriate administrator or supervisor within the operating unit.  However, when there is a potential conflict of interest or for other reasons, such reports may be made to another College official whomthe reporting employee may reasonably expect to have either responsibility over the affected area or the authority to review the alleged improper governmental activity on behalf of the College. When the alleged improper activities involve the President or a Vice President, such reports should be made to the General Counsel. All employees who receive such reports should immediately report them to the General Counsel, who will participate in the investigation.
  4. When a person reports allegations of suspected improper activities to an appropriate authority the report is known as a protected disclosure . College employees and applicants for employment who make a protected disclosure are protected from retaliation.
  5. The General Counsel will forward (1) a report on each allegation of suspected improper activities to the Chair of the Audit Committee of the College’s Board of Trustees, and, when appropriate, the President, and (2) a follow-up report on actions taken in response.
  6. The Audit Committee may enlist outside legal, accounting or other advisors, as appropriate, to conduct any investigation of complaints regarding financial statement disclosures, disclosure concerns or violations, accounting, internal accounting controls, auditing matters or violations of the College’s policies.

B. Protection from Retaliation

Any employee who believes he or she has been (1) subjected to or affected by a retaliatory conduct for reporting suspected unlawful activitiy,  or (2) for refusing to engage in activity that would result in a violation of law, should report such conduct to the appropriate supervisory personnel (if such supervisory personnel is not the source of or otherwise involved in the retaliatory conduct). Any supervisory employee who receives such a report, or who otherwise is aware of retaliatory conduct, is required to advise the General Counsel, of any such report or knowledge of retaliatory conduct. If the Employee believes that reporting such conduct to the appropriate supervisor is for any reason inappropriate, unacceptable or will be ineffectual, or if the report to the supervisor has been made and the retaliatory conduct has not ended, the Employee should report the incident directly to the General Counsel.

All internal complaints will be investigated promptly and with the discretion, and all information obtained will be handled on a "need to know" basis. At the conclusion of an investigation, as appropriate, remedial and/or disciplinary action will be taken where the allegations are verified and/or otherwise substantiated.

C.  Other Remedies and Appropriate Agencies

In addition to the internal complaint process set forth above, any Employee who has information concerning allegedly unlawful conduct may contact the appropriate government agency or call the California State Attorney General Hotline.

Approved by: _______________________________________