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 Values- Driven 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 messages  For purpose of conducting University business  accounts and information sent via University 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: Web reporting address:

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-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

 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.

 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:

 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:  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 Workplace Environmental Health & Safety Department of Human Resources Employee Safety Orientation

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

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

 For further guidance:  The Department of Children and Families 24 hour hotline  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 1 st  Campus Security Authorities (CSAs)  Significant responsibility for campus and student activities  Reporting requirements for timely warnings and crime statistics  Clery Compliance Department  