1. Western Washington University
ETHICS IN WASHINGTON
STATE HIGHER EDUCATION
AND
WESTERN’S POLICIES AND FINANCES
New Employee
Orientation
WWU Office of
The Internal Auditor
Rev

2. Presentation Objectives
Obtain an understanding of:
The Office of the Internal Auditor,
The Ethics In Public Service Act and related regulations,
Other key state laws,
University’s policy web site, and
Common university financial terms and concepts

3. Office of the Internal Auditor
Director, Matt Babick
Senior Internal Auditor, Paul Schronen
Assistant to Internal Audit and Assistant Attorney General, Suzanne Baker
We are located in Old Main 330F. Our mail stop is 9015.

4. About the Office of the Internal Auditor
The Internal Audit Office is committed to assisting Western’s Board, management and staff in achieving their oversight, operating and management responsibilities through independent reviews designed to evaluate and promote the system of internal controls established by management.
To accomplish this, Internal Audit performs different types of services.

5. Types of Internal Audit Services
Perform Audits (Operational, financial related, and compliance)
Consultation Reviews
Special Investigations
Advice and Training
We are available to answer questions in person, over the phone, or through the Contact the Internal Auditor web form on
our web site.

6. External Auditors
In addition to the university’s internal auditors, you may encounter external auditors on campus. The university has contracted with an external auditor to perform annual financial statement audits. Also, auditors from the State Auditor’s Office perform an accountability and compliance audit at Western every year.
Enough about auditors…

7. Ethics In Public Service Act
All university employees, including student employees, are “state” employees.
As such, we are responsible for complying with the Ethics In Public Service Act (Chapter RCW).
In general, the ethics law establishes minimum standards of conduct and provides guidance.
State employees hold a public trust that obligate us to honesty and integrity in fulfilling our university responsibilities.
We are obligated to conserve and protect state resources for the benefit of the public interest, not for private gain.

8. Ethics Training Additional, in depth training is available at -
Human Resources Training web site ( )
Executive Ethics Board web site ( )
(Also, you can contact Internal Audit for more information if you have specific ethics-related questions.)

9. 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

10. Ethics Law Covers The law covers a number of topics, including,
Appropriate use of resources
Conflicts of interest
Personal financial interests
Receiving gifts
Confidential Information
Compensation for outside activities
Receiving honoraria payments

11. Using University Resources
The part of the law that is most applicable to all state employees is using resources.
The law defines how resources should and should not be used.
You can always, of course, use university resources to perform university work.

12. What is a University Resource?
Resources include, but are not limited to: your state compensated time, university phones, fax machines, computers, printers, office space, system, internet access, and tools.

13. Personal Use – De Minimis Rules
You are allowed to make personal use of resources as long as you follow the de minimis rules, and your use is not prohibited. (see subsequent slide)
To be considered de minimis:
There must be little or no cost to the state,
The use is brief and occurs infrequently,
The use does not interfere with the performance of any employee’s duties, and
The use does not compromise the security or integrity of state property, information or software.

14. “Brief” and “Infrequent” Criteria
In a Frequently Asked Question published by the Executive Ethics Board, brief and infrequent means –
“…the use is no more than once a day and lasts a few minutes…”

15. More Restrictive State Rules for Motor Vehicle Use
The rules issued by the Office of Financial Management state that motor vehicles may only be used for “official state business…”, therefore no personal use is permitted.

16. Prohibited Uses of Resources
According to the Ethics law, the following uses
are expressly prohibited:
Conducting outside business or work,
Performing or facilitating illegal activities,
Campaigning or opposing/promoting a ballot issue
Taking any university property for personal use (even if it is going to be thrown in the trash)
Supporting/promoting/soliciting for an outside organization or group (except as noted on the next slide)

17. Supporting, Promoting or Soliciting for an Outside Organization or Group
The Ethics law prohibits using university resources for supporting, promoting the interests of, or soliciting for an outside organization or group.
The Ethics law does allow the use of university resources for supporting, promoting the interests of, or soliciting for an outside nonprofit organization IF it is allowed for in law or is authorized by the President or a Vice President.

18. Examples of Using Technology Resources
Personal use of – Yes*
Use computer for outside work - No
Occasional and limited use of internet – Yes*
Send a Happy Birthday wish – Yes*
Include WWU address on outside work or activity documents – No
Forward jokes to other employees – No
Download games and programs - No
(* Follow de minimis rules)

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

20. 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.

21. Conflicts of Interest
University employees may not have an interest (financial or other) or engage in a business, transaction, 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.

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

23. 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 if you have specific gift questions.)

24. 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

25. Now, a few other important laws that you should be aware of….

26. Public Records Act
Washington law allows open public access to all state public records, except for those that are exempt from disclosure.
University records relating to the conduct of university business are public records.
University’s Public Records Officer (x2728) must be immediately notified of public record requests received by departments. The law requires that the Public Records Officer respond to requests within 5 working days of receipt of the request.

27. State Whistleblower Act
This law encourages state employees
to report improper governmental actions to SAO.
The State Auditor’s Office investigates the allegations and maintains confidentiality of the complainant.
This law protects the complainant and others that participate in a Whistleblower investigation against retaliation or reprisal.
Web site -

28. State Whistleblower Act – Report Designees
Effective June 12, 2008, Western employees may
make Whistleblower reports to the following
University report designees:
Eileen Coughlin, Senior VP for Enrollment and Student Services
Matt Babick, Internal Audit Director
Brent Carbajal, Provost and Vice President for Academic Affairs
Rich Van Den Hul, Vice President For Business and Financial Affairs
Chyerl Wolfe-Lee, Human Resources Director

29. Reporting Loss of Funds & Other Illegal Activities
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.
Departments must retain documents and may not enter into repayment agreements with employees.
Known or suspected violations of the Ethics In Public Service Act must be reported to SAO.

30. Many of the laws covered in the previous slides are covered in university policies….

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

32. Finally, a few slides to provide you with a
basic understanding of a few financial
and accounting terms used at Western…

33. Financial Responsibilities At Western
“Financial Managers” are those employees at Western that are responsible for financial transactions and fund balances. They are responsible for projecting revenues and expenditures, ensuring that all transactions are appropriate for the fund, the ending year fund
balance is positive, and that there are
sufficient internal controls. Financial Managers
may delegate some responsibilities to another
employee that is referred to as a “Budget Authority.”

34. Use of State/University Funds
The university’s monies may only be used for university business purposes.
These monies are accounted for in the university’s financial system in “Chart 1” funds.
We all play a role in being good stewards of the public’s money.

35. Determining Appropriate Use of University Funds
Here are a few questions to help determine the appropriate way to spend university monies:
Does expenditure serve a public purpose?
Is there a fair exchange of goods
or services?
Does the expenditure appear to
provide a personal benefit?
Does expenditure comply with laws and university policies?

36. WWU Foundation Funds
WWU Foundation is a separate legal entity that solicits donations for the university’s benefit. These monies are recorded into “Chart 2” funds in the financial system.
Monies are donated for “restricted”
or “unrestricted” purposes and can only be spent in accordance with the donor’s intentions.

37. Use of “Unrestricted” Foundation Funds
Foundation funds that are not restricted for a specific purpose by the donor must be spent, in general, to support an administrative or academic purpose…not to provide a personal benefit. For example,
Allowable Uses: Scholarships, Fellowships, Academic Program Support, specific departmental events (search committees) and misc. expenses (hiring and moving new hires)
Disallowed Uses: Parking permits or tickets, travel to non-work events, and personal gifts.

38. Welcome to Western !!
If you have any questions or comments, don’t hesitate to call the Internal Audit Office or drop by to see us.
Director, Matt Babick , Old Main 330J
Senior Internal Auditor, Paul Schronen , Old Main 330K
Assistant to Internal Audit and Assistant Attorney General, Suzanne Baker , Old Main 331