Whistleblower Procedures Audit, Finance and Budget Committee has determined that it should establish a formal procedure for the confidential submission by employees of Spelman College of any concern regarding questionable accounting, internal accounting controls, matters related to purchasing, spending, other financial matters or auditing matters. For that purpose, the Committee hereby designates the Secretary of the College as the representative who should initially receive any such concerns. Employees must submit written comments or concerns in writing and in confidence or anonymously to the Secretary of the College. It shall be the responsibility of the Secretary of the College to protect the anonymity of the person submitting any such written statement of complaint or concern. The Secretary of the College shall forward all complaints received to the Chair of the Audit Subcommittee who shall have the authority to appoint either internal or external personnel to investigate the complaint if appropriate. The Audit Subcommittee Chair shall receive the investigative report and in consultation with the full Committee dispose of the complaint as appropriate. To ensure adequate information is provided, when submitting a concern or complaint, the employee should provide the following typed information: background information; nature of complaint; and indicate if the complainant has talked to management. No employee of Spelman College may retaliate or take any adverse action against anyone for raising or helping to resolve an accounting or integrity concern. Employee protection and anonymity shall be guaranteed to the extent possible to employees following the procedures here. Policy No.  118  Effective Date:  5/1/2008