Kenyon College Compliance Line Memo

Recent years have brought a good deal of disturbing news about corporate accounting scandals. The names Enron, WorldCom, and Tyco have become synonymous with the worst in accounting and auditing practices-practices that have harmed not only the companies but also their employees and shareholders. In response, Congress passed the Sarbanes-Oxley Act. This law, which applies to for-profit, publicly traded companies, establishes rules that protect investors by improving the accuracy and reliability of corporate disclosures as well as by providing guidance for best practices in accounting and auditing. The financial legislation passed last year also reinforced the corporate whistleblower provisions of the Sarbanes-Oxley Act.

Kenyon College is not covered by this legislation, because it is a nonprofit institution and does not have shareholders. Nevertheless, many people do have a stake in Kenyon's financial health and future: students, parents, alumni, bondholders and employees. Recognizing this, the Board of Trustees has voluntarily adopted some measures contained in the act. The one that has the greatest relevance for employees is a "whistleblower" provision for reporting fraudulent activity.

The Budget, Finance and Audit Committee of the Board oversees the investigation of "whistleblower" tips that are received in the context of the Sarbanes-Oxley Act regarding accounting practices, misrepresentations, discrepancies, fraud, or any illegal activity involving the assets of the College. The College maintains an anonymous telephone hotline to receive calls concerning suspected instances of accounting or auditing fraud or the misuse or misappropriation of College assets. The hotline is available 24 hours a day, 7 days a week, 365 days a year. It is provided by an independent service with a staff of trained compliance risk specialists that document callers' concerns and forward them anonymously, and only , to the Budget, Finance and Audit Committee. The Committee then begins an investigation.

Kenyon's dedicated hotline number is: 1-800-738-3054.

The College's financial records are regularly audited by an outside independent accounting firm and the Board is particularly pleased with the quality of Kenyon's financial results and system of internal controls. However, although not widespread, the College has encountered several acts of theft and fraud involving college assets over the past several years and Kenyon has been assisted by employees reporting issues to the hotline.

If you are aware of accounting or auditing fraud, or the misuse or misappropriation of College assets, please consider reporting the problem via the hotline.