Transcript Document

Office of Audit, Compliance & Ethics
University Code of Conduct and the Importance of
Individual Behaviors
"reflects the covenant that an
organization has made to uphold its
most important values, dealing with
such matters as its commitment to
employees, its standards for doing
business and its relationship with the
community."
Driscoll, Dawn-Marie and W. Michael Hoffman, Ethics Matters: How to Implement ValuesDriven Management, 2000, p. 77.
 Sets basic standards of workplace behavior
 States publicly the University’s long-term
commitment to the highest standards of integrity
 Assures that faculty, administrators and staff
understand their shared responsibility for keeping the
University in compliance
 Education
 Research
 Patient Care
 Campus-wide
 Business, Fiscal and Legal
 External Relations and University Advancement
Conduct of Faculty, Administrators and Staff
 Members of the University community shall perform their duties
in a fair and ethical manner in accordance with established
policies, procedures and regulations.
 Members of the University community shall carry out their
duties with professionalism.
 Supervisors have a particular responsibility to support the Code
of Conduct and to demonstrate compliance within their units.
 Code of Conduct – Campus-Wide Standards
 The University’s computer and telecommunication networks are
University resources that are provided to employees, students and
volunteers to allow them to carry out the functions of the institution
 University Policy – Electronic Communication Policy
 Expected to read all University email messages
 For purpose of conducting University business
 Email accounts and information sent via University email services are
the property of the University and subject to public records laws and
state records retention rules
 No expectation of privacy
 Consult the Code of
Conduct
 Seek guidance from
appropriate individuals
or offices
 Violations may result in
appropriate disciplinary
measures
Individual Responsibility
Institutional Success
 If you wish to report a concern or a suspected violation
anonymously you may contact the University’s REPORTLINE
 Available 24 hours a day, 7 days a week
 Independent specialists trained to obtain complete and
accurate information in a confidential manner
Phone: 1-888-685-2637
Web reporting address:
https://uconncares.alertline.com/gcs/welcome
University policy prohibits
retaliation if you report in
good faith a compliance
concern to any supervisor,
faculty, administrator, the
Compliance Office, the
REPORTLINE or any
appropriate agency outside
of the University
Office of Audit, Compliance & Ethics
University Guide to the State Code of Ethics
We, as employees of the State of
Connecticut, adhere to the
guidelines set forth in the
Connecticut Code of Ethics for
Public Officials, as well as the
University’s Guide to the State
Code of Ethics
 Part of the Connecticut General Statutes
 Intended to prevent individuals from using their
public position or authority for personal financial
benefit
 University’s policy is based upon the State Code
A conflict of interest (COI) occurs when an individual’s
personal interests diverge from his/her obligations as a
state employee.
COI may take many forms including:
 Gifts
 Outside Employment
 Financial Benefit
 Contracts with the State
 Appearance fees
 University employees generally may not accept gifts,
discounts or gratuities from “prohibited donors”:
 Anyone doing or seeking to do business with the
University
 Anyone engaged in activities directly
regulated by the University
 A lobbyist (current list can be found on
the Office of State Ethics website)
 A contractor pre-qualified by
Department of Administrative Services
(DAS)
Gift exceptions:
 Items offered to the public at large
 Items valued at less than $10 with annual total equaling
less than $50
 Food and beverage less than $50 total in a calendar year
from each donor and only if the person paying is in
attendance
 Gifts valued at less than $100 from a supervisor or
subordinate
 Major life events
 Gifts to the state
University employees may not:
 Use their state position to obtain another job
 Use state resources for their outside employment
 Compromise independent judgment
 Disclose confidential information from state service
 Benefit the private employer in any way through
their official actions
Employees may not:
• promote
• advertise
• solicit
personal business
through use of state
resources
 No employee may be the direct supervisor of or
take any action which would affect the financial
interests of one’s relative
 Relative – spouse, child, step-child, child’s spouse,
parent, brother, sister, brother-in-law, sister-inlaw, dependent relative or a relative domiciled in
the employee’s household
 When confronted with a possible decision or action
involving a relative, must inform immediate
supervisor in advance in writing
 If presented with a conflict of interest, must prepare
a written statement
 Discuss with their immediate supervisor
 The supervisor should assign the matter to another
employee who does not directly or indirectly report
to that individual
 Form to assist employees with this requirement
COI Form
Faculty & AAUP Members State Ethics Exemption:
 Activity cannot be related to state employment
 Activity is related to expertise
 Must receive compensation (except royalties)
 If compensation is only coverage of travel expenses – and the
faculty member will not net any compensation – a consulting
form is not needed. Instead, a necessary expenses form (and
possibly a travel request) are required.
UPDATE:
 Employees who choose to employ students in any non-University
activity must obtain written approval from their Department
Head/Dean/Director prior to employing the student
 Must receive a written offer of employment with a specific
scope of work or job description, the rate of compensation and
the expected hours of work
 Fair market value rate of pay
 Ongoing recourse to the Provost
 Outside employment letter template available here:
http://policy.uconn.edu/?p=1077
 May not accept fees/honorarium for
appearances, speeches or articles written in
an official state capacity
 Applies if state position was a significant
factor in being asked
 “Necessary expenses” may only be accepted
for items for which the University would
otherwise pay
 Reported directly to the
Office of State Ethics
within 30 days of
receiving payment or
reimbursement
Unless an open and public process has been
completed:
Employees and their family members or
business associates may not enter into a
contract (valued at $100 or more) with
the state
 Has moved to Research Compliance Services
 FCOI processes will be streamlined to decrease
administrative burden on UConn’s investigators
 Electronic
 Annual and when changes occur
 Policies will be harmonized to simplify procedures
 One common set of criteria regardless of sponsor
 The FCOI team is helping UConn’s investigators to manage
potential conflicts of interest, allowing them to engage in
external activities
 Consult
 Start a company
 Employees are not prohibited from seeking political
office as long as it is not done on State time or with
State equipment
 No employee of the University will engage in
partisan political activities while on state time
 No employee will use state materials or equipment
for the purpose of influencing a political election
 You may never use confidential information for
financial gain
 You may not represent anyone concerning any
matter in which you personally and substantially
participated while in state service
 You may not, for one year, represent anyone
before your former agency for compensation
 If you participated substantially in the negotiation
or award of a state contract valued at $50,000 or
more, you may not accept employment with a
party to the contract for one year after leaving
state service, if you resign within one year after
the contract was signed
Office of Audit, Compliance & Ethics
Health and Safety
We are responsible for
complying with all workplace
safety and health regulations
and will report unsafe
conditions, equipment or
practices to appropriate
University officials, as
required by law
The health and safety of all students, faculty, staff,
and visitors shall be a principal consideration in the
planning and conduct of all University activities and
programs
All members of the University should:
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Report concerns immediately
Get trained and keep training current
Follow procedures
Use Personal Protective Equipment
Managers/Supervisors should:
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Identify and correct health and safety concerns
Ensure employees/students receive training
Provide information on policies and procedures
Provide and require the use of Personal Protective Equipment
Model safety
Staying
SafeSafety
in theOrientation
Workplace
Employee
Environmental Health & Safety
Department of Human Resources
Working Alone means an isolated individual working with an
immediately hazardous material, equipment or in an area that, if
safety procedures fail, could reasonably result in incapacitation
and serious life threatening injury for which immediate first aid
assistance is not available
Immediately Hazardous Environment describes any material,
activity or circumstance that could cause instantaneous
incapacitation rendering an individual unable to seek assistance
Unit Managers are managers, supervisors, principle investigators,
faculty, Department Heads and others who are responsible for
assigning work to students that involve potential exposure to
immediately hazardous environments.
Under this policy Unit Managers are
responsible to:
 Identify and document Immediately
Hazardous Environments on the
Workplace Hazard Assessment
 Minimize risk associated with student
academic work
 Establish effective safety
monitoring/means of communication
for students
 Ensure students are aware of and
comply with this policy
UPDATE:
Virtually all University Employees are Mandated
Reporters
 Child abuse occurs when a child under the age of 18 has had
physical injury inflicted upon him or her other than by
accidental means, has injuries at variance with history given of
them, or is in a condition resulting in maltreatment, such as,
but not limited to, malnutrition, sexual molestation or
exploitation, deprivation of necessities, emotional
maltreatment or cruel punishment
 Child neglect occurs when a child under the age of 18 has been
abandoned, is being denied proper care and attention physically,
emotionally, or morally, or is being permitted to live under
conditions, circumstances or associations injurious to his wellbeing
 For further guidance:
http://www.ct.gov/dcf/cwp/view.asp?a=2556&Q=314384
 The Department of Children and Families 24 hour hotline
1-800-842-2288
 REMINDER: Any employee who has witnessed or received a
report of a sexual assault must comply with the University’s
Sexual Assault Response Policy by reporting to ODE, regardless
of the age of the victim.
 Annual Security and Fire Report
 Distributed by October 1st
 Campus Security Authorities (CSAs)
 Significant responsibility for campus and
student activities
 Reporting requirements for timely warnings
and crime statistics
 Clery Compliance Department
 www.clery.uconn.edu
 860-486-5181