Communications
Whistleblower Policy
Objectives and Purpose
Carleton College is committed to integrity, transparency, and full compliance with federal and state laws. The objectives of this policy are to:
- Formally establish procedures to help provide a workplace conducive to raising potential concerns and to open discussion of the business practices of the College;
- Positively reinforce and influence compliance with federal and state laws;
- State how members of the community can report concerns, including suspected fraud, false claims, or misuse of government funds; and
- Explain what the Federal False Claims Act and Minnesota False Claims Act are and how they apply to the College.
Employees, contractors, volunteers, agents, and representatives of Carleton College are expected to practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations. The purpose of this policy is to comply with all applicable laws that protect individuals who report concerns against unlawful discrimination or retaliation by their employer as a result of their lawfully reporting information regarding, or their participating in, investigations involving fraud or other violation by the College or its agents of federal or state law.
Whistleblower Protections
Both federal and state law protect individuals who report fraud, waste, or abuse from retaliation. You are protected if you: (1) report in good faith; (2) participate in an investigation; and/or (3) assist in a legal action involving a false claim.
You cannot lose your employment, or be demoted, harassed, or discriminated against for reporting suspected fraud.
If retaliation occurs, you may be entitled to reinstatement to your position, back pay, and compensation for damages (including attorney’s fees).
No Retaliation
No covered individual who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the College prior to seeking resolution outside the College.
State and Federal Law
The Federal False Claims Act makes it illegal to knowingly: (1) submit a false or fraudulent claim for payment using government funds; (2) use false records or statements to support such claims; or (3) conspire with others to defraud the government.
“Knowingly” includes actual knowledge, deliberate ignorance (choosing not to know) and reckless disregard for the truth.
Penalties may include fines, treble damages, and legal costs. Private individuals who report fraud may sue on the government’s behalf and receive a share of any recovered funds.
The Minnesota False Claims Act prohibits false or fraudulent claims involving state funds or property. Under this law, it is illegal to (1) submit or cause the submission of a false claim for state payment; (2) use false records or statements to support such claims; (3) conspire to commit fraud; (4) deliver less than the full amount of public funds or property owed; (5) deliver a false receipt intending to defraud; (6) illegally buy or receive government property; or (7) submit false records to reduce a debt owed to the state.
Penalties for violation of the Minnesota False Claims Act include fines and damages.
Examples of False or Improper Claims
Some examples of what might constitute a false claim include: (1) knowingly fabricating data on reports submitted for federal or state funding; (2) submitting false or misleading information in research grant reports or certifications; (3) inflating expenses or creating fake vendor invoices for reimbursement from public funds; or (4) knowingly misstating enrollment or demographic information that affects funding.
Reporting Violations
In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to use the whistleblower reporting hotline to report any potential violations. (Username: Carleton and Password: Reports) or by calling 1-877-778-5463. Supervisors and managers are required to report suspected violations to Human Resources.
Compliance Officer
The Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at their discretion, shall advise the President and/or the Audit Committee of the Board of Trustees. The Compliance Officer has direct access to the Audit Committee and is required to report to the Audit Committee at least annually on compliance activity. The Compliance Officer is appointed by the Audit Committee.
Accounting and Auditing Matters
The Audit Committee of the Board of Trustees shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The Compliance Officer shall immediately notify the Audit Committee of any such complaint and work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of federal or state law. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously to the whistleblower reporting hotline. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations
Complaints filed through the whistleblower hotline can be tracked through the reporting system. All reporting will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.
Last Revised: October 9, 2025
Approved by the Audit Committee of the Board of Trustees, May 16, 2007. Revised and approved by the Board of Trustees, October 9, 2025.
Last Reviewed: October 20, 2025
Maintained by: Human Resources