Code of Ethical Conduct

Summary of Policy

Provides guidance on expected ethical conduct for those who are part of the Dartmouth community, including trustees, faculty, staff, and student employees ("Dartmouth Personnel").

Affected Parties

All Groups

Policy Statement

Dartmouth Personnel Responsibility

  • Become familiar with the Code of Ethical Conduct and applicable Administrative Policies.
  • Nurture a culture distinguished by integrity, quality, trust, openness, diversity, inclusion, and respect.
  • Maintain engagement and report any breaches of the Code of Ethical Conduct or Administrative Policies.


It is the goal of Dartmouth College to adhere to the highest ethical standards in all that it does. Dartmouth College expects that those who are part of the Dartmouth community, including trustees, faculty, staff, and student employees ("Dartmouth Personnel") will adhere to such standards in their dealings with each other and with those beyond the Dartmouth community. Ethical conduct calls for all Dartmouth Personnel to assume responsibility for safeguarding and preserving Dartmouth's assets and resources in the fulfillment of its mission. Dartmouth will comply fully with all relevant laws and all contract and grant requirements, as well as with its own high standards of integrity and quality. Dartmouth Personnel are expected to assume personal responsibility and accountability for understanding relevant laws, regulations, and contract and grant requirements. In addition to complying with specific laws or regulations that govern business activities, standards of fairness, honesty, and respect for the rights of others will govern Dartmouth's conduct at all times.


a. Compliance with Laws

Dartmouth College will transact its business in compliance with the laws of the jurisdictions in which it does business. Dartmouth Personnel will familiarize themselves with any legal obligations arising out of the work done for Dartmouth, including but not limited to the obligations to comply with applicable recordkeeping requirements and not to retaliate against anyone who reports a suspected violation of the law. If questions arise regarding compliance with the law, or if it appears that one of Dartmouth's policies conflicts with the relevant law, the person who becomes aware of that situation should contact the office at Dartmouth that has oversight responsibility for the policy, or the Office of the General Counsel.

b. Contractual and Grant Obligations

In addition to its commitment to comply with applicable laws, Dartmouth College recognizes its contractual obligations to donors, the government, suppliers, research sponsors, employees, and others with whom it contracts. Regardless of the source of funds, Dartmouth College will adhere to its contractual obligations.

c. Integrity and Quality

Dartmouth Personnel should recognize that Dartmouth College has earned and must maintain a reputation for integrity and quality that goes beyond compliance with laws, regulations, and contractual obligations. Dartmouth strives for excellence in administration as well as academics. Even the appearance of misconduct or impropriety can cause severe damage to Dartmouth's reputation. As such, Dartmouth Personnel must strive at all times to maintain the highest standards of quality and integrity.

d. Diversity, Equity & Inclusion

Diversity at all levels is critical to Dartmouth's mission of providing an environment that combines rigorous study with the excitement of discovery. As an institution of higher education, Dartmouth is defined by the belief that a multiplicity of backgrounds, values, beliefs, interests, experiences, as well as intellectual and cultural viewpoints enrich learning and inform scholarship.

Respect for the cultures that make Dartmouth a dynamic teaching, research and service environment is a bedrock institutional value. Dartmouth's Division of Institutional Diversity & Equity provides resources to promote inclusive practices across all of Dartmouth's working and learning environments.

e. Conflicts  

All Dartmouth Personnel, including employed students, should avoid situations that create or appear to create conflicts between their personal interests and Dartmouth's interests. All decisions made by Dartmouth Personnel in the course of their professional responsibilities are to be made solely on the basis of their desire to promote Dartmouth's best interests. If an individual's personal interests might lead an independent observer reasonably to question whether the individual's actions or decisions on Dartmouth's behalf are influenced by those personal interests, the individual should recuse themself from the decision-making process and notify the responsible Dartmouth officials, as described in more detail in the Conflict of Interest Policy. Prior to accepting an external commitment, Dartmouth Personnel must discuss the proposed commitment with their supervisor to ensure it will not result in a conflict or the appearance of a conflict and discuss annually.  In addition, it is Dartmouth's policy to comply in all respects with state and federal laws concerning conflicts, including but not limited to the New Hampshire Pecuniary Benefit Law, which governs transactions between New Hampshire charitable organizations and their trustees and officers. Further information concerning the Pecuniary Benefit Law may be obtained from the Office of the General Counsel.

f. Confidential Information

Dartmouth Personnel may have access to confidential, proprietary, and/or private information. Those who have access to this information may not make any unauthorized use or disclosures of the information, either during or after employment.

g. Data Governance and Protection

Data at Dartmouth is managed through an approach where employees have key roles safeguarding information by implementing information security policies, standards, and controls. To this end, Dartmouth has adopted a comprehensive security policy for the processing, transmission, and storage of information, including electronic, paper, and other media.  All Dartmouth offices, employees (faculty and staff) and users of information and technology services must comply with the institutional information security policy and apply the standards and controls that are applicable to the Dartmouth information they manage and use.  Students, alumni, and others who have access to Dartmouth information must also comply with this policy. Applicability is determined by the data classification, which is determined by factors including the nature of the information, the risks of unauthorized disclosure or corruption of the information, and relevant regulatory requirements.

h. Antitrust Considerations

Dartmouth is committed to full compliance with federal and state antitrust laws, which prohibit collusion among competitors and other business practices that undermine competition. For this reason, Dartmouth Personnel should avoid agreements—express or implied—or exchanges of information with other colleges and universities that reduce competition among institutions. Dartmouth Personnel should never enter into agreements with other colleges or universities regarding tuition, fees, financial aid, recruitment of students or faculty, or employee compensation. In addition, Dartmouth Personnel should not share any confidential-business information with other colleges or universities without conferring with the Office of General Counsel. Confidential-business information is any information that Dartmouth would not normally share with the public or other universities or schools, including strategic plans, marketing strategy, confidential aspects of the admissions process, and confidential financial information. Dartmouth Personnel who have affiliations with other colleges and universities (e.g., on the board of trustees of another institution) should not disclose Dartmouth's confidential-business information to the other institution, or vice versa.

i. Financial Reporting

All Dartmouth financial information, including financial reports, tax returns, expense reimbursements, time sheets, and other documents, including those submitted to government agencies, must be accurate, clear, and complete. All entries in Dartmouth's books and records, including departmental accounts and individual expense reports, must accurately reflect each transaction. Retention of these documents shall conform to established Dartmouth record retention policy.

j. Authority to Contract

All transactions must be authorized by appropriate individuals and conducted in accordance with Dartmouth's Signature and Requisition Authority Policy. Individuals who enter into contracts on Dartmouth's behalf should confirm the extent of their authority to do so on a regular basis.

k. Accepting Gifts

Employees representing the College are expected to uphold the integrity of the institution while conducting business with outside organizations, vendors, and individuals. All employees are expected not to compromise any business transaction in exchange for personal benefit such as gifts. Promotional items of an advertising nature, an occasional business meeting meal, or items of insignificant value, not to exceed the value of a business meeting meal, are acceptable. Gifts outside of these guidelines would be deemed unacceptable and shall be returned.

l. Additional Administrative Policies

Additional and more detailed and explicit policies may govern particular areas of administration such as human resources, finance, information technology, or research. It is the responsibility of each person working in those areas to learn and adhere to those policies. A selection of related policies is provided below. Additional policies may be found by visiting departmental web pages.

m. Consequences of Violations of Dartmouth's Policies

Each person is responsible for ensuring that their own conduct and the conduct of anyone reporting to them fully comply with this Code and with Dartmouth's policies. Violations may result in the taking of appropriate disciplinary action up to and including discharge from employment or fiduciary appointment. Disciplinary action will be taken in accordance with the procedures applicable to faculty, staff, or employed students, as the case may be. Conduct representing a violation of this Code may, in some circumstances, also subject an individual to civil or criminal charges and penalties.


a. Reporting to Management

Dartmouth Personnel should report suspected violations of applicable laws, government regulations or Dartmouth policies, government or industrial contract and grant requirements, or this Code. This reporting should normally be made initially through standard management channels, beginning with the employee's immediate supervisor. Alternatively, employees may go directly to Human Resources, Institutional Diversity and Equity, Safety and Security, Internal Controls Services, Chief Compliance Officer, the Office of the Executive Vice President, or the Office of the General Counsel, to report suspected violations or problems. In these cases, people may look to the Dartmouth College Integrity Helpline. The Helpline can be accessed either through a toll-free number (888-497-0516) or through a website: The telephone number and website are owned and hosted by EthicsPoint, not Dartmouth. Reports can be made anonymously, but this is not required. In either case, providing as much information as possible will aid Dartmouth in its investigation of the reported concern. You can find more information on the Integrity and Compliance webpage:

The channels of reporting described in this Code are not intended to supersede specific grievance or other procedures established for particular situations. Where applicable, community members are advised to utilize such procedures. See, examples:

b. Cooperation

All employees should cooperate fully in the investigation of any misconduct.


Questions about this Code may be directed to the Chief Compliance Officer or the Office of the General Counsel.


The Integrity and Compliance Office shall periodically review this Code and recommend any amendments for review and approval by the Senior Leadership Team.


Policy ID


Effective Date

February 13, 2024

Last Revised Date

June 9, 2023


Office of the President

Office of Primary Responsibility

Office of the General Counsel (OGC)

Office of Primary Responsibility