Ethics and Conflicts of Interest

All employees should attempt to avoid personal transactions or situations in which their personal interests will, or appear to, conflict with those of the University.

Consistent with the Internal Revenue Service ("IRS") regulations and guidelines on Intermediate Sanctions and Excise Taxes on Excess Benefit Transactions, Washington and Lee University ("University” or “W&L"), a charitable, educational institution, desires to maintain the highest standards of accountability and transparency in governing University operations. Therefore, trustees and officers of the University, as well as other individuals in certain positions of influence (collectively referred to as “Interested Persons,” and further defined in Section B), must discharge their duties and manage the affairs of the University in its best interests and observe duties of care and loyalty to W&L. Interested Persons must be fully informed about and closely monitor transactions and arrangements in which any person who is in a position to exercise substantial influence over the University’s affairs may have a personal economic or other interest.

This policy is designed to protect the University’s interests when it considers entering into a transaction, arrangement, or association that might provide a personal economic or other benefit to any Interested Person or Interested Entity (as defined below) at the expense of the University’s best interests (financial or otherwise). Compliance with the procedures listed herein (Section II.B) is further intended to allow W&L to rely upon the rebuttable presumption that its transactions and relationships with Interested Persons and Interested Entities are not excess benefit transactions as defined by the Internal Revenue Code, 26 U.S.C. § 53.4958-6(c).

Washington and Lee University is committed to the highest standards of ethics and integrity. The University has determined that having Finance Personnel sign the Code each year serves as our promise that we will maintain these high standards. Signed copies are maintained in the Business Office.

This policy is intended to guide the University’s financial aid officers and staff - as well as any other employees or agents who otherwise have responsibilities with respect to education loans at the University - in the ethical execution of their professional responsibilities, in accordance with the Higher Education Opportunity Act of 2008.

The ethical principles of Washington and Lee University derive from one of the two fundamental objectives of the University, as set forth in its Statement of Ethical Philosophy: “ . . .to pursue its educational mission in a climate of learning that stresses the importance of the individual, personal honor and integrity, harmonious relationships with others, and the responsibility to serve society through the productive use of talent and training.” Faculty and staff employees of the University are expected to commit themselves to these fundamental institutional objectives and to uphold the highest ethical standards while acting on behalf of Washington and Lee University in discharging its business and academic affairs.

Washington and Lee University ("the University") has a responsibility for the stewardship of its resources and the private support that enables it to pursue its mission. The Board and administration are committed to compliance with the laws and regulations to which the University is subject and to promulgating University policies and procedures to interpret and apply these laws and regulations in the University setting. The University’s internal controls and operating procedures are intended to detect and to prevent or deter fraudulent or dishonest conduct, and/or violations of law (referred to hereinafter as “improper activities"). However, even the best systems of control cannot provide absolute safeguards against improper activities. Intentional and unintentional improper activities may occur. The University has a responsibility to investigate and report to appropriate parties allegations of suspected improper activities and to report the actions taken by the University. The University will investigate any alleged Improper Activities and may discipline any individual found to have engaged in such conduct, up to and including dismissal from the University. W&L reserves the right to refer such conduct for civil and criminal prosecution. All members of the W&L community are encouraged to report possible Improper Activities. Employees (including student employees) should report concerns to their supervisor/department head. Students not working for the University should report their concerns to the supervisor/department head of the University employee whom they believe to be engaging in such improper activity. W&L supervisors and department heads are required to report any concerns brought to them, and any situations in which they suspect improper activities, to their Vice President, the relevant Dean, the Provost, or the Office of General Counsel. If, for any reason, an individual finds it difficult to report his/her concerns to the relevant supervisor/department head, he/she may report the matter to the relevant Dean or Vice President, or Office of General Counsel, in the manner set forth in the procedures below. W&L Cognizant Policy Officers and Compliance Partners under the University’s Protocol for Implementation of the Matrix Compliance Program are authorized to communicate personally with the Chair of the Audit Committee on the compliance program and/or possible criminal conduct that could expose the University to liability.