Board of Trustees bears the ultimate responsibility for setting ethical standards and ensuring they permeate the organization and inform its practices. The following ethical and whistleblower policies are approved by the Board of Trustees on July 9, 2011.

Ethics Policy

(a) Executive Compensation.

Compensation for officers, directors and key employees will be determined by person(s) who have no financial interest in the determination and who have done a review of comparable positions. From time to time, the Board of Trustees will review compensation as noted in the Bylaws of the Corporation.

(b) Conflict of Interest.

The trustees of a charity owe it a duty of loyalty. The duty of loyalty requires a trustee to act in the interest of the charity rather than in the personal interest of the trustee or some other person or organization. In particular, the duty of loyalty requires a trustee to avoid conflicts of interest that are detrimental to the organization. The Board of Trustees will review any conflicts of interest on an annual basis.

(c) Investments.

The Board of Trustees will evaluate its participation in any investments on a bi-annual basis and take steps to safeguard the organization’s assets and exempt status if they could be affected by the investment arrangement. The Board will adopt policies and procedures prior to the use of an investment advisor or any joint venture or similar investment arrangement.

(d) Fundraising and Donor Policies.

The Board will have oversight responsibility for fundraising solicitations. Board members or administrative staff will prepare fundraising materials that are accurate, truthful, and candid. They will also ensure all fundraising solicitations meet the requirements of federal and state law. Donor policies will also be posted to the organization’s website.

(e) Finances.

The Board of Trustees is the steward for Kepler’s finances and other resources. It will review financial statements on a regular basis. The Board will also review the IRS Form 990 prior to its filing with the Internal Revenue Service. From time to time, the Board may establish an independent audit committee to review Kepler’s finances and/or select and oversee an outside financial review or audit by and independent auditor.

The Board will review the IRS Form 990 prior to its filing with the Internal Revenue Service. The Board will also ensure that copies of Kepler’s IRS Form 990s are available for public inspection online through the GuideStar website. The IRS Form 1023 will be available on the Kepler website. A notice will be placed on the Kepler website that Board policies and financial statements are be available upon request.

Whistleblowing Policy

Kepler College is committed to lawful and ethical behavior in all of its activities and requires its employees to conduct themselves in a manner that complies with all applicable laws and regulations. If at any time a concern exists regarding the propriety or legality of any action contemplated to be taken or that has been taken by any Kepler trustee, employee, faculty, student, contractor, or vendor, as the action relates to Kepler’s activities, or if an action needs to be taken in order for the Kepler to be in compliance with law or appropriate ethical standards, any trustee, employee, faculty, student, contractor, vendor can address the issue directly by going to the President or a member of the Board of Trustees as needed until matters are satisfactorily resolved.

If any person does not believe that these channels of communication can/should be used to express their concerns, s/he may contact any other board member or administrative officer. Under this policy (sometimes referred to as a “whistleblower policy”), those who report illegal or improper activity will be protected. Efforts will be made to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. The individual making the report will not be discharged, threatened, harassed, or discriminated against for reporting in good faith what they perceive to be wrongdoing, violations of law, or unethical conduct.