Stevenson University (“the University”) and its full-time and part-time faculty and staff (“employees”) must comply with applicable federal, state, and local laws and regulations at all times. The University expects employees to follow the highest standards of honest conduct and business ethics in all aspects of their activities on behalf of the University. The University will not tolerate action in the course of employment or arising from employment that violates law or is unethical.
This Code of Conduct identifies basic policies and standards concerning ethical conduct and provides guidance in several areas of specific concern. Employees are expected to assume personal responsibility and accountability for their actions by maintaining these standards.
In an effort to ensure employees are adequately informed of the University’s expectations, they will be required to affirm that they have read this Code of Conduct. The conduct required by the University in this Code is not limited to the specific areas for which guidance is given herein.
Compliance with Laws and Regulations
Employees are expected to transact the University’s business in compliance with all federal, state, and local laws and regulations related to their positions and areas of responsibility, including, but not limited to, the following: equal employment opportunity, fair employment practices and nondiscrimination, the privacy and confidentiality of employee and student records, workplace safety, and occupational health.
Conflicts of Interest
Employees must avoid conflicts of interest that might compromise the integrity and objectivity of the University. Examples include, but are not limited to, the following: working for the University as an outside vendor, misusing or misappropriating proprietary information to benefit oneself or a person or entity outside the University; utilizing discounts allowed to the University for one’s personal gain; and profiting oneself or a third party by facilitating business or service between the University and outside parties.
Financial conflicts of interest (e.g., employee participation in the ownership or affairs of an entity or with a person that regularly does business with the University) must be fully disclosed to the University and, thereafter, either sanctioned by the University or eliminated by the employee, as the case may be. No employee may approve, recommend, or promote a transaction with a business in which the employee is an officer, director, in senior management, or holds more than a five percent (5%) interest, unless such employee first fully discloses both the potential conflict and contemplated transaction to the President’s Office and CFO.
All employees who intend to apply for government funding must contact the Office of Sponsored Programs & Research (OSPR) to complete disclosure forms to determine whether a financial conflict of interest (FCOI) might exist. This requirement applies to all individuals who are responsible for the design, conduct, or reporting of research or programs whose financial interests would reasonably appear to be affected. An FCOI exists when any of the following apply:
- With regard to any publicly traded entity, any remuneration received from an entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated exceeds $5,000.
- With regard to any non-publicly traded entity, any remuneration received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator’s immediate family members) holds any equity interest (e.g., stock, stock option, or other ownership interest); or
- Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income in excess of $5,000 related to such rights and interest.
Financial conflicts of interest will be managed or eliminated. The investigator’s name and financial conflict will be made available upon request. Required training on FCOI will be provided through the OSPR.
Refer to the FCOI Plan on the Stevenson University OSPR webpage for the disclosure form and expanded details. These will be reviewed annually and revised as needed.
Except for reasonable business entertainment and customer gifts of nominal value, employees must not receive anything of value by solicitation or gift in return for influencing or exercising their discretion in any University matter. Employees must not accept any material gift, gratuity, or other payment, in cash or in kind, from any vendor currently doing business or soliciting new business with the University. Employees must not solicit or receive personal discounts or rebates on goods and services from University vendors that exceed those generally available to the vendors’ other customers.
Employees must avoid any activity that hinders their ability to carry out their responsibilities to the University.
Kickbacks, Gifts, and Other Forms of Secret Payments
Employees must not make or accept payments or compensation to improperly obtain or reward favorable treatment in connection with either a contract or subcontract relating to a prime contract. The University strictly prohibits the acceptance of kickbacks and all other practices that smack of secret payoffs from suppliers or others. Any breach of this rule will result in immediate termination of employment.
Employees must not accept entertainment, gifts, or favors for personal use that could, in any way, influence, or appear to influence, business decisions in favor of any person with which the University has, or is likely to have, business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their position with the University might be inclined to, or be perceived to, place them under obligation.
The University’s educational mission is promoted by professionalism in faculty, staff, and student relationships. Professionalism is fostered by an atmosphere of mutual trust and respect. Actions of faculty, employees and students that harm this atmosphere undermine professionalism and hinder fulfillment of the University’s educational mission. Trust and respect are diminished when those in position of authority abuse, or appear to abuse, their power. Those who abuse their power in such context violate their duty to the University community.
University Funds, Assets and Property
Employees who have access to University funds in any form must follow the prescribed procedures for recording, handling, and protecting the funds. When an employee’s position requires spending University funds or incurring any reimbursable personal expenses, the Employee must use good judgment to ensure the University receives good value.
Employees are responsible for safeguarding the tangible and intangible assets of the University that are under their control. University funds, assets and equipment are for University purposes only and must not be converted to personal use, either for oneself or another.
University Records and Reporting
The records, data and information owned, leased, borrowed, used, and managed by the University must be kept accurate and complete. The accuracy and reliability of financial reports are of utmost importance to the business operations of the University. Employees must record, allocate, and charge costs accurately and maintain supporting documentation as required by established policies and procedures. All reports, vouchers, bills, invoices, payroll information, personnel records, and other essential business records must be prepared honestly and with care.
Obligation to Report Suspected Violations
Employees are obligated to report suspected violations of these policies and standards promptly to their supervisor, department chair, or Vice President. A supervisor or department chair to whom a report of a violation is made is obligated to follow up the report with the appropriate administrative authority. In investigating claims of inappropriate activities, care will be taken to maintain confidentiality. The University will not tolerate retaliation toward or harassment of employees who disclose perceived wrongdoing in a good faith, appropriate, and reasonable manner.
The University may take disciplinary action against employees who violate this Code of Conduct. Disciplinary sanctions may include, but are not limited to, loss of compensation, reassignment, demotion, suspension, and termination. Furthermore, if a violation of this Code also constitutes a violation of law or regulations, employees may be subject to civil or criminal sanctions.
Compliance With This Code of Conduct
Employees are required to ensure their own compliance with this Code. Employees are expected to use sound judgment in recognizing situations in which a violation of this Code may occur and ensure that none occurs. If an employee is unsure of this Code’s applicability under the facts and circumstances of the situation, it is incumbent upon the employee to seek the advice of a supervisor and/or Human Resources.
Employees who supervise others should ensure that those they supervise receive adequate instructions and explanations with respect to their obligations under this Code. Failure of a supervisor to report actual or possible violations may subject such supervisor to University discipline.
(Approved July 2018)