Ethics and Integrity Officer and Program

Gettysburg College is committed to operating with integrity and in compliance with all applicable federal and state laws, regulations, and policies. To further these commitments, the Board of Trustees has established an Ethics and Integrity Program (the Program), which is organized as follows (see attached organizational chart). The Board shall provide oversight of the Program, which in most cases shall be delegated to the Board Audit, Compliance and Risk Committee.

1. The Program shall include the following key elements:
   1. Designation of a high-level leader, the Ethics and Integrity Officer, for day-to-day management of the Program;
   2. Standards of Conduct;
   3. Program related polices, which can be found in the Gettysburg College Policy Library
   4. Program related training;
   5. A confidential Campus Conduct Hotline (CCH);
   6. A process for following up and investigating alleged fraud, violation of criminal law, external compliance, or significant reputational risk, including a process for disciplining those who violate the Standards of Conduct or Program policies;
   7. A process for identifying and evaluating key risks; and
   8. A process for periodically assessing the effectiveness of the
2. The Structure of the Program includes the following:
   1. An Ethics and Integrity Officer who is responsible for the day-to-day management of the Program, and has a dual reporting relationship to the President and the Chair of the Audit, Compliance and Risk Committee of the Board of Trustees
   2. A management-level committee, the Ethics and Integrity Executive Steering Committee, and the College Ethics and Integrity Committee to provide advice and support to the Ethics and Integrity In most cases, the President’s Council will serve as the Ethics and Integrity Executive Steering Committee. The Ethics and Integrity Executive Steering Committee is responsible for advancing the effectiveness of the Program by providing advice and support to the Ethics and Integrity Officer in the discharge of her/his responsibilities. The Ethics and Integrity Officer chairs the College Ethics and Integrity Committee which is composed of representatives from each of the College divisions and assists with implementation of the Program.
      1. A Board-level committee, in most cases the Audit, Compliance and Risk Committee, to provide governance oversight.
      2. Ethics and Integrity Liaisons, who work under the direction of the Ethics and Integrity Officer to ensure that their departments are in compliance with the Program.
   3. The Ethics and Integrity Officer will regularly communicate information related to the Program to the President, the Audit, Compliance and Risk Committee, and to the Board of Trustees.

Gettysburg College Ethics and Integrity Organizational Chart

Ethics and Integrity Officer Job Description

Reporting: Administratively, the Ethics and Integrity Officer reports to the President with a dotted-line reporting structure to the Chair of the Audit, Compliance and Risk Committee.

Role and Responsibilities

1. Lead and provide oversight of the College’s Ethics and Integrity Program to assure compliance with legal, regulatory, policy and ethical requirements impacting the College.
2. Develop, revise as necessary and monitor implementation of the College’s Ethics and Integrity plan, consistent with higher education emerging best
3. Provide oversight of Ethics and Integrity risk assessment
4. Develop, revise as necessary and monitor implementation of Ethics and Integrity program
5. Provide oversight of Ethics and Integrity program training and
6. Provide oversight of the College’s Ethics and Integrity Assure that questions and concerns raised through the hotline are promptly and appropriately addressed.
7. Provide oversight of all Ethics and Integrity related investigations, working with outside counsel as
8. Chair the College’s Ethics and Integrity
9. Provide ethics and integrity program updates at regular meetings of the Audit, Compliance and Risk Committee.
10. Provide oversight for periodic, independent assessment of the effectiveness of the Ethics and Integrity
11. Apprise the President and senior management, the Chair of the Audit, Compliance and Risk Committee of the Board of Trustees, and the Board of Trustees about the College’s Ethics and Integrity Program; trends, issues, and best practices in ethics and integrity
12. Apprise the Audit, Compliance and Risk Committee Chair in a timely manner of matters described below (unless prohibited by law or in deference to an ongoing investigation by a law enforcement agency).
    1. Actual or Alleged Fraud - Matters involving actual or alleged instances of material fraud by employees, including but not limited to theft, and regardless if the fraud involves the For purposes of applying this reporting and communication framework, materiality is defined as amounts exceeding $10,000 in aggregate.
    2. Violation of Criminal Laws – Matters involving actual or alleged criminal acts (other than summary offenses) perpetrated by a Trustee, College Officer, Department Director, or Academic
    3. External Compliance Violation – Matters required to be referred to or otherwise involving a governmental entity (e.g. a Federal, State or local oversight agency), as well as matters triggering an external reporting obligation, other than matters reported in the ordinary course of business.
    4. Reputational Risk - Other ethics and compliance related matters that pose a high probability of garnering significant negative publicity or media
    5. Other Matters – Other significant ethics and compliance related matters that, in the judgment of the Ethics and Integrity Officer, warrant reporting to the Audit, Compliance and Risk Committee
13. Report all matters described above to the President, who will in turn apprise the Chair of the Board of Should any matter described above directly involve the President, the Ethics and Integrity Officer will report the matter directly to the Chair of the Board of Trustees as well as the Audit, Compliance and Risk Committee Chair. Should any matter described above directly involve the Ethics and Integrity Officer, the President will report the matter directly to the Audit, Compliance and Risk Committee Chair as well as the Chair of the Board of Trustees.