Western Washington University ETHICS IN WASHINGTON STATE ACADEMIA AND WESTERN’S POLICIES AND FINANCES New Faculty Orientation Fall 2008

Ethics In Public Service Act The Ethics In Public Service Act (Chapter Revised Code of Washington) applies to all university employees, including student employees. The ethics law establishes minimum standards of conduct and provides guidance for ethical choices. State employees are obligated to conserve and protect state resources for the benefit of the public interest. State employees may not use state resources for private gain.

Ethics Training Available on Human Resources Training web site (on-line tutorial) ( Available through the Executive Ethics Board ( ) -On-line quiz and training handouts

Ethics Law Covers Appropriate use of resources Compensation for outside activities Gifts – Including restrictions if you have purchasing decision authorities, compensation for reviewing textbooks and disposing of review textbooks Personal Financial Interests – Including authored textbook use in Western’s classes Receiving honoraria payments Conflicts of Interest Confidential Information …and more

Use of Resources Rules Can always be used for university work Personal use of university resources is allowed but you must follow the de minimis rules: –There is little or no cost to the state –It is brief, infrequent and effective use of the resource –It does not interfere with work –It does not disrupt business or other employees or obligate them to make personal use –It does not compromise security of state property

Prohibited Uses of Resources The following uses are not allowed by law: –To conduct outside business or work –For illegal activities –For campaigning, opposing or promoting ballot issues or candidates –Taking any university property for personal use, even if it is going to be thrown in the trash –Using a resource and then reimbursing the university for the cost –Supporting an outside entity (including charities) UNLESS it is approved by the President, Provost or Vice President

Use of – Examples Personal use – Yes* Use for outside work - No Send a Happy Birthday wish – Yes* Include WWU address on outside work or activity documents – No Forward jokes to other employees – No (* Follow de minimis rules) (Note: You are not responsible for receiving unsolicited messages, however you are responsible for what you do with these s such as forwarding them to other employees.)

Use of Internet & Computer – Examples Search topics or issues on-line from your computer in your office or non-public area – Yes* Buy products on-line – No Download software – No Play pre-loaded games – Yes* Personal outside business - No (* Follow de minimis rules)

Use of Resources for Political Purposes Prohibited Activities: Using work time to solicit signatures, raise funds, or campaign for or against a candidate or ballot measure Using university facilities for political purposes, even after work hours Displaying political materials in or on university vehicles or facilities. EXCEPTION: The free speech issue of wearing campaign buttons or placing such materials in personal assigned spaces must be balanced with the obligation to not use visible public facilities to post such materials.

Using Resources For Outside Consulting or Business Outside Work: Is any activity performed by a state employee that is paid for by anyone other than Western Washington University, WWU Foundation or WWU Alumni Using any university resources to perform any work for your outside business or private employment is prohibited Exception: Employees may follow the university’s Patent and Copyright policy

Compensation for Outside Activities Compensation may be accepted when: There is a bona fide contract and work was performed The performance or administration of the contract is not within your Western duties You would not be inappropriately assisting outside persons or organizations You are not working for someone that you can not accept a gift from You did not create this outside work opportunity through your capacity at Western You would not be required to make a disclosure of confidential information

Receiving Gifts Employees should not accept gifts or anything of value if it could be reasonably expected to influence your vote, judgment or action Employees should generally not accept gifts in excess of $50 from a single source per year If you can make purchasing decisions, the gifts that you can accept are limited to a specific list (Contact Internal Audit for more information)

Faculty Accepting Compensation to Review a Textbook Faculty must use caution to ensure that they are not accepting a gift or thing of value that may influence their decision A faculty member’s decision may be considered to be influenced if: - They are required to select the textbook in order to receive the compensation, or - The compensation is “substantial”

Disposing of Evaluation Textbooks University employees may accept evaluation, review, courtesy or desk copies of textbooks as long as they are related to the recipient’s official duties at Western These textbooks can be disposed of by giving them to the university, donating to a charity within 30 days, or by using the university’s surplus process Faculty may not sell the textbooks and donate the proceeds to a charity

Authored Faculty Using Their Textbook In Western’s Classes The Ethics Act states that employees may not make decisions in transactions that would beneficially interest the employee Since Western wants its faculty to author textbooks and other academic documents, a chair or committee* can select/delegate the use of the textbook in the authored faculty member’s classes or in other faculty member’s classes *Must not include the authored faculty member

Receiving Honoraria Payments An honorarium is any money or thing of value offered for a speech, appearance, article or similar item in connection with your official role at Western. An honorarium can only be accepted if approved by the university and is not specifically prohibited by the Ethics law. ( te= ) te=

Conflicts of Interest University employees may not have an interest (financial or otherwise, direct or indirect) or engage in a business or transaction or professional activity or incur an obligation that is in conflict with the proper discharge of the employee’s official duties at Western Conflicts of interest may be remedied by disclosure or abstaining from participating in a decision or action.

Confidential Information University employees may not disclose confidential information gained during official duties or otherwise use confidential information for personal gain or benefit University employees must not intentionally conceal a record that they know should be released under the Public Disclosure Act

Public Records Law Establishes a strong policy for accessing public records unless records are exempt A public record is any university record relating to the conduct of university business University’s Public Records Officer must be notified of public record requests received by departments because the law requires that the PRO respond to requests within 5 working days of receipt

University Policies The university has many policies which were written to define employee’s responsibilities as well as educate and guide employees in understanding rules and expectations of state employment. The university’s policies are located at New faculty members are encouraged to review the web site to become familiar with the university’s policies.

University Policy Highlights Using University Resources (Covers general use rules) Policy on Consulting and Other Compensated Professional Activities (In Faculty Handbook) Responsibilities of Financial Managers Reporting Loss of University Funds Safeguarding Non-Public Financial Information Many other policies in cash handling, purchasing, accounting, contracts, human resources, billing and health and safety

Responsibilities of Financial Managers Revenues and expenses are projected All transactions are appropriate for the fund Fund should not have negative balance at the end of the fiscal year There are proper internal controls such as monitoring and separation of duties May delegate authority to others to initiate & approve transactions (but can not delegate ultimate responsibilities)

Reporting Loss of Funds Policy The university is required by law to report known or suspected loss of public funds or assets or other illegal activities to the State Auditor’s Office. The policy and procedure outline who should be called and when. Violations of the Ethics In Public Service Act are reportable conditions.

WWU Employees May Report Concerns To: Direct supervisor or department or division superior State Auditor’s Office Whistleblower Program State Executive Ethics Board WWU Office of the Internal Auditor WWU Human Resources Department WWU Equal Opportunity Office WWU Police (Immediate safety concerns - Call 3911)

State Whistleblower Act The Act encourages state employees to report improper governmental actions The State Auditor’s Office investigates allegations and the Whistleblower Act ensures confidentiality of complainant The complainant is protected against retaliation or reprisal Web site -

State Whistleblower Act - Update Effective June 12, 2008, Western employees may now make Whistleblower reports to the following designees: Wendy Bohlke, Assistant Attorney General Kim Herrenkohl, Internal Audit Director Dennis Murphy, Provost George Pierce, VP for Business and Financial Affairs Bruce Shepard, President Chyerl Wolfe-Lee, Human Resources Director

Internal Audit Can Investigate Concerns Western employees may report allegations of improper governmental actions to Internal Audit Internal Audit handles all complaints as confidentially and discretely as possible Complainants can use the anonymous Contact the Internal Auditor form on the Internal Audit web site to report concerns ( The complainant is protected against retaliation or reprisal

State Ethics Board Ethics Board receives complaints and performs investigations of alleged ethics violations Ethics Board web site at contains: –Contact information –Frequently Asked Questions –Links to RCW and WAC –Training information –“Enforcement” page (list of violations & penalties) –Official Advisory Opinions –Newsletters and Brochures

General Accounting Concepts at Western University (state) funds and how to determine whether or not an expenditure is appropriate WWU Foundation funds - restricted and unrestricted expenditure rules

Use of University Funds University funds may only be used for university business purposes. These funds are referred to as “Chart 1” funds. We all need to be good stewards of the public’s monies.

When Determining Appropriate Use of University Funds Does expenditure serve a public purpose? Is there a fair exchange of goods or services? Does expenditure appear to provide a personal benefit? Does expenditure comply with laws and university policies?

WWU Foundation Funds WWU Foundation is a separate legal entity that solicits donations for the university’s benefit. These funds are referred to as “Chart 2” funds. They can be donated for specific (restricted) purposes or for more general university or college use purposes, often referred to as “unrestricted”.

Use of ANY Foundation Funds Can only be spent in accordance with the donor’s intentions. In general, if it is a personal expense, it is disallowed. If it is a work-related expense, it is allowable (subject to donor’s intent). WWU Foundation has published guidelines that assist the campus in understanding the rules for spending Foundation funds.

Use of “Unrestricted” Foundation Funds There can be misunderstanding about the appropriate use of “unrestricted” Foundation funds. –Allowable: Scholarships, Fellowships, Academic Program Support, specific departmental events (search committees) and misc. expenses (hiring and moving new hires) –Disallowed: Parking permits or tickets, travel to non- work events, personal gifts and department social events for birthdays or personal recognitions.

A long habit of not thinking a thing wrong gives it the superficial appearance of being right. Thomas Paine

Welcome to Western Washington University Please don’t hesitate to call the Office of the Internal Auditor with your questions or comments. We are here to help you during your transition and throughout your career at Western. Kim Herrenkohl, Director Shu-Ling Sun, Staff Auditor