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