Office of Audit, Compliance & Ethics University Code of Conduct and the Importance of Individual...
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Transcript of Office of Audit, Compliance & Ethics University Code of Conduct and the Importance of Individual...
2015 Compliance TrainingOffice of Audit, Compliance & Ethics
University Code of Conduct and the Importance of Individual Behaviors
Code of Conduct"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 Values-Driven Management, 2000, p. 77.
Purpose of the Code of Conduct 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
Standards
Education Research Patient Care Campus-wide Business, Fiscal and Legal External Relations and University Advancement
Example: Campus-wide StandardsConduct 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.
Everyday Example: Email
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
Individual behaviors Consult the Code of Conduct
Seek guidance from appropriate individuals or offices
Violations may result in appropriate disciplinary measures
Individual Responsibility Institutional Success
REPORTLINE
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
Non-Retaliation
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
2015 Compliance TrainingOffice of Audit, Compliance & Ethics
University Guide to the State Code of Ethics
EthicsWe, 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
State Code of Ethics for Public Officials
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
University Guide to the State Code of EthicsA 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
Gifts 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)
Gifts
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
Outside Employment
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
Outside Employment
Employees may not:• promote • advertise • solicitpersonal business through use of state resources
Employment and Contracting for Service of Relatives
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-in-law, 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
Conflict of Interest Disclosure 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 Consulting
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: Use of Students in Outside Employment 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
Appearance Fees
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
Necessary Expenses Reporting
Reported directly to the Office of State Ethics within 30 days of receiving payment or reimbursement
Contracts with the State
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
Financial Conflict of Interest - Research
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
Dealing with any conflict of interest starts with recognizing a real or potential conflict……and asking questions
Political Activity 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
Post-State Employment 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
2015 Compliance TrainingOffice of Audit, Compliance & Ethics
Health and Safety
Health & 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
University Health & Safety Policy
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
Shared ResponsibilityAll members of the University should: Report concerns immediately Get trained and keep training current Follow procedures Use Personal Protective Equipment
Managers/Supervisors should:
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 Safe in the WorkplaceEnvironmental Health & Safety
Department of Human Resources
Employee Safety Orientation
Working Alone Policy
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.
Working Alone PolicyUnder 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: Child Abuse and Neglect Reporting
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 well-being
Child Abuse and Neglect Reporting 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.
Clery Act Reminder 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