code of conduct and

ethical standards

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 message from the president
A commitment to the highest standards of ethical conduct is integral to the history and
culture of the University of Vermont. The Latin motto on our university seal, “Studiis et
Rebus Honestis,” Integrity in Theoretical and Practical Pursuits, traces to our earliest years
and, to this day, succinctly captures the spirit of honesty and integrity at the foundation
of our endeavors.

This same commitment inspired “Our Common Ground,” a UVM document that broadly
Affirms values such as openness, respect, and justice and their essential place in the fabric
of our campus community. Upholding the core principles of “Our Common Ground”
requires the commitment of the university as a whole and all of us as individuals.

At a more sharply focused level, an array of university policies provides standards and guideposts designed to aid us in our work, our
decisions, and our actions. These policies hold us to the ideals we aspire to and expect of one another. As this page is a gateway to
these policies, I invite members of the university community to explore and familiarize yourselves with the policies, and return to
them for guidance as particular questions or situations arise. When more assistance or explanation is needed, please contact
Compliance Services for help.

The integrity of our institution and the respect it enjoys is dependent upon all of us being committed to ethical behavior and being
familiar and compliant with university policies. Thank you for your attention to these critical issues.
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code of conduct and ethical standards
 table of contents
page
4
introduction
page
12
reporting, non-retaliation & disciplinary action
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19
health, safety & campus environment
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22
fiscal compliance & asset management
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29
research
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32
freedom of expression
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35
conclusion – resources, policy references, related documents & contacts
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code of conduct and ethical standards
introduction

“Integrity
“Integrity is
is doing
doing the
the right
right thing
thing
even
even when
when nobody
nobody isis watching.”
watching.”

-C.S.
-C.S. Lewis,
Lewis, Novelist,
Novelist, Academic
Academic (1898
(1898
–– 1963)
1963)

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 Much of what we need to know about compliance risks is intuitive. However, recognizing risks can sometimes be more
difficult than it seems.

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introduction: what? 55
 code statement
Both UVM’s motto and “Our Common Ground” illustrate the
University’s commitment to strengthening our culture of compliance.
As a member of the University community, we all need to be aware
of our own conduct and how that affects the University as a whole.

We are all expected to perform our jobs and to

conduct university business ethically and in
Compliance with the laws, acts, statutes, regulations and policies and procedures that
pertain to our jobs. We all have a responsibility to the University, to those we serve, to
our community and to each other.

An effective compliance program will take us from being reactive when a violation is uncovered to being
proactive and preventing the violation from happening in the first place. In other words, if you read, understand
and follow this code, you can go from having to stomp out forest fires to blowing out a match.

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introduction: what? 66
 reason for the code
The goal of a compliance program is to get everyone behaving ethically at all times
and in all situations. Your code of conduct is one tool that you can use when you
are faced with a difficult situation, an ethical dilemma or when you’re not sure what
the right decision is.

Very few people show up to work with the intent to break the law. Sure, it does happen,
but most people want to do the right thing. Regardless of what our individual roles are
at UVM, we may be faced with an ethical dilemma or may just need clarification on a
regulation, law, policy or procedure. That is what your code of conduct is designed to
help with. It’s why the Board of Trustees stands behind the code and why having an
effective compliance program is so important to the mission of the University.

We all have a responsibility to do the right thing, even when nobody is watching. We owe this to each other and to those that we serve. Most
importantly, we all need to recognize that we are all in this together.

While it is impossible to list out every dilemma or difficult situation that could arise, there are some areas that are more risky to the University. At the
very least, we should all be aware of those areas of highest risk within our jobs. Your manager or supervisor should be able to provide you with guidance
in these areas. This code can help you find the answers.
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introduction: why? 77
 applicability of the code

Your code of conduct and ethical standards applies to all University of Vermont
personnel.

For the purpose of this code, personnel means faculty, staff, volunteers, student
employees, and anyone hired or contracted to perform duties that are generally
associated with an employment relationship (such as a temporary employee or a
graduate student that is getting paid through the University).

Anyone considered University of Vermont personnel should read the code. If

you read it and don’t understand something, please ask. Contact your manager
or supervisor or any member of the Office of Audit & Compliance Services with
questions or for clarification.

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introduction: who? 88
 applicability of the code
If the code applies to you, you must comply with the requirements in the code. There are some common excuses
for non-compliance. Some of the more common “excuses” for non-compliance are:

customary practice expediency fear of retaliation

“We’ve always done it this “I didn’t have time.” or “We “My manager told me to be quiet and stop
way.” don’t have enough staff.” complaining or I’d be fired.”

Regardless of your title or position, these excuses do not justify unethical or illegal behavior. If you ever feel
as if you are being put in a situation to do something illegal or unethical, you have a place to go for help.
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introduction: who? 99
 office of audit & compliance
services structure
The Office of Audit & Compliance Services is structured this way in order to provide both the audit and theChairperson
complianceof the
functions the independence and autonomy needed to run
Audit Committee of
successful programs. the Board of Trustees

With a direct reporting line to the Board, the Chief Internal Auditor has independence from operations and has the ability to bring compliance issues and risks directly to the
Chief Audit Officer
Board.

The Director of Compliance Services reports to the Chief Audit Officer. This provides the Director
Director with
of the same independence from operations that is needed to have an
effective compliance program.
Compliance Services

Office of Compliance Office of Audit

Both offices work together but have very different functions and purposes.
Services Services

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introduction: how? 10
10
 oversight and structure
of the compliance program Responsible
Official:
President
The Board of Trustees has a responsibility to take reasonable steps to make
sure the compliance program is effective. The Director of Compliance Services
is the person that the Board has delegated the day-to-day oversight
Oversight
Oversight of
of the
the program
program & &
responsibility to. While the Office of Compliance Services is responsible for responsibility
responsibility for this code
for this code of
of
the operation of the compliance program, we are all individually responsible conduct:
conduct:
to be aware of and comply with the legal and regulatory requirements and Office
Office of
of Compliance
Compliance Services
Services
with University policies and procedures that apply to our jobs.

In addition, some professions may have additional compliance

obligations through professional organizations or licensing agencies. Operational
Operational responsibility
responsibility for
for most
most operational
operational compliance
compliance
areas:
areas:
In order for your compliance program to work up to its research,
research, AAEO,
AAEO, finance,
finance, risk
risk management
management & & safety,
safety, legal,
legal,
human resources, information technology, athletics,
human resources, information technology, athletics,
potential, everyone needs to be an active participant. privacy,
privacy, police,
police, facilities
facilities
Communicate concerns, let someone know when you are
having difficulty following a procedure. Those of us who
are the “doers” are the first ones to recognize a possible
problem. Let someone know.
Day-to-day
Day-to-day responsibility
responsibility for
for actions
actions that
that could
could result
result in
in aa compliance
compliance violation:
violation:
YOU

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introduction:
introduction: how?
how? 11
11
 code elaboration
It may be difficult to know at what point you need to report a
concern. Depending on the concern, you may have mandatory
reporting requirements. For example, state law requires that certain University personnel report suspected child abuse. Also, under the Clery Act
which is a federal law, Campus Security Authorities (CSA’s) are required by law to report suspected criminal activity to UVM Police Services.

Even if not required by a regulation, you may feel a moral or ethical obligation to report something. Under your Code, you are encouraged to report
any suspected wrongdoing.

Under
Under your
your Code,
Code, “wrongdoing”
“wrongdoing” means:
means:

•• Real
Real or
or suspected
suspected violations
violations of
of legal
legal and
and regulatory
regulatory requirements
requirements (laws,
(laws, acts,
acts, statutes,
statutes, regulations),
regulations),
policies
policies and
and procedures
procedures and/or
and/or professional
professional standards.
standards.
•• Fraudulent
Fraudulent or dishonest conduct resulting in violation
or dishonest conduct resulting in violation of
of law
law or
or University
University policy.
policy.

It is important to understand that not all reports have to be wrongdoing. The compliance reporting mechanisms are also there for you if you have
questions related to a University process, if you need help making a difficult decision or if you are faced with an ethical dilemma. Sometimes talking
it through can help make the situation or the decision easier.

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introduction: when? 12
12
 reporting,
non-retaliation
& disciplinary action
“Treat
“Treat those
those who
who areare good
good with
with
goodness,
goodness, and and also
also treat
treat those
those who
who
are
are not
not good
good with
with goodness.
goodness. Thus Thus
goodness
goodness is attained. Be honest to
is attained. Be honest to
those who are honest, and
those who are honest, and be also be also
honest
honest to
to those
those who
who areare not
not honest.
honest.
Thus
Thus honesty
honesty is is attained.”
attained.”

-Lao
-Lao Tzu,
Tzu, Philosopher,
Philosopher, Poet
Poet (601
(601
BC–
BC– 531 BC)
531 BC)

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13
 compliance reporting
system
We all have a responsibility to report violations to any regulations, laws, acts, statutes,
UVM policies, procedures or to this Code of Conduct. Just because ”I am not involved”,
“it doesn’t affect me”, or “it’s none of my business” does not mean we should turn a blind
eye to it. When we become aware of wrongdoing and fail to tell someone, at some level,
we become involved in the wrongdoing.

To assist you with reporting, your compliance program provides you with multiple ways that you can report wrongdoing or suspected wrongdoing.
The University has created a policy called “Whistleblower Policy: Reporting, Protections, & Non-Retaliation” that provides details on all of the ways
you can report.

This does not mean that all reports must come to the Office of Compliance Services. You can report to the Office
of Compliance Services but there is no requirement to do so. If there is another policy that gives us information on
reporting requirements, we should always follow that policy. If there isn’t a policy, if you’re just not sure where to
go or if you’ve reported something elsewhere that hasn’t been addressed, use one of the compliance reporting
mechanisms. While the Office of Compliance Services may not be the department that handles the report, we will
be able to guide you in the right direction. The Ethics & Compliance Reporting and HelpLine is always available
to accept reports of wrongdoing.

Ethics
Ethics &
& Compliance
Compliance Reporting
Reporting and
and HelpLine
HelpLine

877-310-0413
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reporting, non-retaliation & disciplinary action
14
14
 available compliance
reporting mechanisms
A report may be made using any of the following reporting mechanisms:

1. Use the reporting process identified in the relevant UVM policy or procedure.
2. Report through UVM’s Compliance and Ethics Reporting and HelpLine. This mechanism provides reporters with the ability to
report anonymously.
• Call toll free: (877) 310-0413
• File a report through the web. Go to our website at www.uvm.edu/compliance and click on the blue Ethics and Compliance Reporting and Helpline
button on the right of the page.
3. Report to the Director of Compliance:
• Phone: (802) 656-0847
• Email: CLICK HERE
• In writing to: Director of Compliance Services, Office of Audit & Compliance, University of Vermont, 48 University Place, Burlington, VT
05405
• In person – Office located in Billings, Room 159 (M-F, 8:30am to 4:00pm, additional times available by appointment.

You can always contact UVM Police Service if you believe that criminal activity is taking place or has occurred.

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reporting, non-retaliation & disciplinary action
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 reporting to managers &
using the helpline
For reports made directly to a manager or supervisor, the manager/supervisor is required
to notify the Director of Compliance or the Office of General Counsel when the manager/
supervisor suspects the report may result in either a violation to legal or regulatory
requirements or fraudulent activity. Managers/Supervisors are encouraged to seek the
advice of the Office of Compliance Services as soon as possible when they receive reports
of alleged noncompliance to a legal or regulatory requirement.

Reports made through the HelpLine are received and screened through a third-party vendor. While some other mechanisms accept anonymous reports,
the best reporting method for maintaining the anonymity for anonymous reports is the HelpLine.
Regardless of the reporting mechanism used, all reports are kept as confidential as possible. However, anonymity
can never be guaranteed.

For more information on the HelpLine, refer to the HelpLine FAQ’s. CLICK HERE

Ethics
Ethics &
& Compliance
Compliance Reporting
Reporting and
and HelpLine
HelpLine

877-310-0413
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reporting, non-retaliation & disciplinary action
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 non-retaliation
As it relates to your Code of Conduct, retaliation means “taking action to harm someone in response to a report.
Retribution means the act of taking revenge. If you report in good faith or if you participate in an investigation and you
are disciplined, harassed, or otherwise treated poorly because of your report, that is retaliation. And, it’s not OK.
Individuals making bad faith reports do not have this same protection.

At UVM, retaliation is not tolerated. Under federal and state law, whistleblowers have additional protection from
retaliation. It doesn’t matter if it’s a supervisor retaliating against a direct report or peers retaliating against peers.
Retaliation is retaliation and it is not allowed.

Those who retaliate against someone may face disciplinary action up to and including termination from employment. The report does not have to be proven – if the report was
made in good faith and it turns out that wrongdoing did not occur and someone retaliates against the person who made the report, that person may be disciplined.

Good-Faith
Good-Faith Reports
Reports
Bad-Faith
Bad-Faith Reports:
Reports:
AAgood
good faith
faith report
report isis aa report
report that
that isis made
made with
with aa sincere
sincere belief
belief that
that the
the issue
issue isis occurring,
occurring, has
has occurred
occurred or
or there
there isis aa
likelihood
likelihood that it will occur. There is no malice or desire to defraud others. In other words, it is made with honesty and
that it will occur. There is no malice or desire to defraud others. In other words, it is made with honesty and A
Abad
bad faith
faith report
report isis aa report
report that
that isis made
made to
to deceive,
deceive, isis dishonest,
dishonest, knowingly
knowingly untrue
untrue or
or
integrity
integrity because
because you you believe
believe itit isis aa problem
problem or
or could
could bebe aa problem.
problem. otherwise
otherwise intentionally misleading. Often times, bad faith reports are lies intended to
intentionally misleading. Often times, bad faith reports are lies intended to
get
get someone
someone in in trouble
trouble or or are
are untrue
untrue andand made
made toto retaliate
retaliate against
against someone.
someone.
For
For example,
example, you
you return
return to
to the
the office
office after
after lunch
lunch and
and see
see your
your boss
boss in
in the
the parking
parking lotlot taking
taking anan envelope
envelope full
full of
of cash
cash
from
from someone
someone and
and sticking
sticking itit in
in her
her purse.
purse. YouYou report
report it.
it. After
After investigation,
investigation, itit turns
turns out
out that
that your
your boss
boss just
just sold
sold aa used
used Using
Using the
the same
same example
example except
except you
you don’t
don’t get
get along
along with
with your
your boss
boss so
so you
you add
add in
in that
that
car
car and
and the
the buyer
buyer met
met her
her during
during herher lunch
lunch toto pay
pay for
for the
the car.
car. you’ve
you’ve seen
seen her
her do
do this
this every
every week
week for
for the
the past
past couple
couple of
of months
months and
and that
that computers
computers
and
and equipment
equipment hashas been
been disappearing
disappearing from
from your
your department.
department.

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reporting, non-retaliation & disciplinary action
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17
 disciplinary action
If wrongdoing occurs, those people who were responsible for the wrongdoing will be
disciplined at a level appropriate to the violation. Disciplinary action is anything from
a verbal warning and up to immediate termination. It could also include termination
of University institutional recognition or external affiliate relationships. Depending
on the type of violation and the University’s regulatory requirements, it could even
include civil claims and criminal charges. There could be violations that the
University is required to report to law enforcement or regulatory agencies.
Investigation and determination of discipline for represented employees will occur in
accordance with provisions of the applicable collective bargaining agreement.

It is important to recognize that we are all in this together and that our actions, or inaction, can have an effect on the University, on
those that we work with and on those that we are responsible to. Disciplinary action is designed to fit the violation and should be
consistent with same or similar violations. Retaliation can take the form of unfair or inequitable disciplinary action and retaliation is
not tolerated at UVM.

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reporting, non-retaliation & disciplinary action
18
18
principles
and
standards
The
The intent
intent of
of your
your code
code isis to
to communicate
communicate thethe principles
principles and
and
standards
standards that
that have
have been
been identified
identified as
as most
most relevant
relevant to
to UVM’s
UVM’s
stated
stated values.
values. This
This is
is not
not aa compilation
compilation ofof every
every policy
policy that
that you
you
are
are responsible
responsible toto comply
comply with.
with. UVM’s
UVM’s policies
policies and
and procedures
procedures
extend
extend beyond
beyond those
those identified
identified in
in this
this code.
code. Those
Those highlighted
highlighted here
here
are
are those
those that
that we
we believe
believe pose
pose the
the greatest
greatest compliance
compliance risk
risk to
to the
the
University.
University.

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 principles
principles &
& standards
standards #1
#1
health, safety &
campus environment
“If
“If we
we are
are to
to achieve
achieve aa richer
richer culture,
culture, rich
rich in
in
contrasting
contrasting values,
values, we
we must
must recognize
recognize thethe
whole
whole gamut
gamut of of human
human potentialities,
potentialities, and
and so
so
weave
weave aa less
less arbitrary
arbitrary social
social fabric,
fabric, one
one inin
which
which each diverse human gift will find aa
each diverse human gift will find
fitting
fitting place.”
place.”

-Margaret
-Margaret Mead,
Mead, Cultural
Cultural Anthropologist
Anthropologist
(1901
(1901 –– 1978)
1978)

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 creating a respectful
campus environment
Under state and federal statutes, it is illegal to discriminate based on
race, color, national origin, religion, sex, disability, certain Veterans, age, citizenship status and genetic information. The State of
Vermont also prohibits discrimination based on sexual orientation, gender identity and related characteristics, place of birth, ancestry,
veteran status, HIV status, and discrimination based on the basis of age as to persons 18 and older.

A diverse UVM community is in all of our best interests.

It is vital to our ability to achieve academic excellence.
When a university is unsuccessful in creating a diverse “Of
“Of all
all the
the civil
civil rights
rights for
for which
which the
the world
world has
has struggled
struggled and
and
community, the quality of their academic programs fought
fought for 5,000 years, the right to learn is undoubtedly the
for 5,000 years, the right to learn is undoubtedly the
suffers. A diverse community will prepare our graduates most
most fundamental.”
fundamental.”
for the ever more diverse world in which they will live -W.E.B.
-W.E.B. DuBois,
DuBois, Sociologist,
Sociologist, Historian
Historian and
and Activist
Activist (1868-1963)
(1868-1963)
and work.

For more information:

Read UVM’s “Why Diversity” Statement: CLICK HERE

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health, safety and campus environment 21
21
 creating a safe and
healthy campus
A safe and healthy campus refers to both environmental safety (i.e.,
buildings, grounds) and personal safety. There are many different areas that are covered under the University’s safety program (see
box - the list is not all-inclusive but provides some examples). When it comes to
a safe and healthy campus, we are all equally responsible for how we behave as
Examples
Examples well as how we treat others. If you ever feel unsafe or if you see or hear about
•• An
An employee
employee is
is subjected
subjected to
to sexual
sexual harassment
harassment byby aa supervisor.
supervisor. unsafe conditions on campus or in your workplace, let someone know. Contact
•• A
A disabled
disabled student
student is
is unable
unable to
to access
access aa building.
building. anyone listed under the resource section of this Code. If you ever feel that you or
•• A
A faculty
faculty member
member becomes
becomes romantically
romantically involved
involved with
with aa current
current
someone else is in immediate danger, call 911.
student
student in
in one
one of
of his
his classes.
classes.
•• You
You suspect
suspect that
that aa co-worker
co-worker is
is buying
buying alcohol
alcohol for
for an
an underage
underage student.
student.
•• A
A University
University employee
employee isis directly
directly responsible
responsible for
for overseeing
overseeing minors
minors
but
but has
has not
not had
had the
the requisite
requisite background
background check
check or
or training.
training.
•• A
A campus
campus security
security authority
authority (CSA)
(CSA) fails
fails to
to properly
properly report
report aa crime
crime that
that
occurred
occurred on
on campus.
campus.
•• You
You observe
observe people
people using
using external
external fire
fire escapes
escapes or
or rooftops
rooftops without
without
authorization.
authorization.
•• You
You observe
observe or
or have
have knowledge
knowledge of
of the
the improper
improper transfer
transfer or
or disposal
disposal of
of
hazardous materials.
hazardous materials.

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health, safety and campus environment 22
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 principles
principles &
& standards
standards #2
#2
fiscal compliance
&
asset
management
“The
“The time
time to
to repair
repair the
the roof
roof is
is
when the sun is shining.”
when the sun is shining.”

-John
-John F.F. Kennedy,
Kennedy, 35
35thth
President
President of
of the
the United
United States
States
(1917 – 1963)
(1917 – 1963)

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 privacy & security of
confidential information
At the University of Vermont, we recognize the importance of protecting the privacy and security of
confidential information. Some of this information is legally protected. Some of of the information
we need to protect is sensitive and, for a variety of reasons, needs to be kept confidential. Whether it
is legally protected or if keeping it confidential is just the right thing to do, the University takes this
responsibility very seriously and demonstrates its commitment through its Information Security and
Privacy Programs. All UVM personnel have a responsibility to maintain the privacy and security of
confidential or sensitive information. Protection of this information can greatly reduce the risk of the
misuse of information or of a breach.

EXAMPLES
EXAMPLES
Examples
Examples ofof Legally
Legally
Protected
Protected Information
Information •• You
You are
are behind
behind in
in some
some work
work soso you
you transfer
transfer some
some research
research data
data to
to aa USB
USB drive
drive to
to take
take home
home with
with you
you over
over the
the long
long weekend.
weekend. TheThe data
data
contains
contains the
the participant’s
participant’s name,
name, social
social security
security number
number and
and research
research results.
results. Your
Your bag
bag that
that contained
contained the
the USB
USB drive
drive is
is stolen
stolen and
and the
the
•• Student
Student Records
Records (FERPA)
(FERPA) data
data was
was not
not encrypted.
encrypted. This
This isis reportable
reportable under
under University
University policy
policy and
and under
under state
state law.
law. Contact
Contact the
the Information
Information Security
Security Office
Office at
at
•• Social iso@uvm.edu.
iso@uvm.edu. Remember that removing unencrypted protected data is not allowed and may also violate contracts, agreements and other
Remember that removing unencrypted protected data is not allowed and may also violate contracts, agreements and other
Social Security
Security Numbers
Numbers
federal or state regulations.
federal or state regulations.
•• Financial
FinancialAccount
Account Information
Information
•• AA parent
parent calls
calls and
and wants
wants information
information on
on her
her child
child who
who recently
recently turned
turned 18.
18. The
The information
information contains
contains FERPA
FERPA protected
protected education
education records.
records.
•• Protected
Protected Health
Health Information
Information
(HIPAA)
You
You cannot
cannot disclose
disclose the
the information
information without
without the
the student’s
student’s permission.
permission. Disclosing
Disclosing without
without permission
permission isis considered
considered aa violation
violation of
of FERPA.
FERPA.
(HIPAA)
•• You
You suspect
suspect that
that someone
someone isis using
using your
your UVM
UVM login
login ID
ID and
and password
password to
to gain
gain access
access to
to financial
financial information.
information. Even
Even ifif you’re
you’re not
not sure,
sure, you
you
should report this to the Information Security Office at iso@uvm.edu.
should report this to the Information Security Office at iso@uvm.edu.

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fiscal compliance & asset management 24
24
 privacy & security of
confidential information
Hacking. Phishing. Spam. Adware. Spyware. Trojan
Horses. Malware. Worms. Cookies. Loss. Theft. Social
PHISHING Engineering. These are all words that in some way, shape,
Trying to trick a computer or form, pose a threat to the University. And, information
user into giving up their is not just an “information technology problem”. It is an
personal information by
looking like a legitimate
“all of us problem” and we are all equally responsible to
company. protect against the misuse of information, equipment and
assets of the University.

INFORMATION SECURITY
Working together to protect our
information systems in order to
reduce the risk of unauthorized
disclosures or a breach
DATA BREACHES
Under Federal and State law,
UVM is required to report
breaches of personal information
and protected health information.
Anyone with a UVM login and password has responsibility. Those with access to personal,
private, confidential, sensitive or otherwise protected information regardless of the form or
format (electronic, paper, recorded, verbal, etc.) have even greater responsibility.
As security technology becomes stronger, the “bad guys” are focusing more and more on trying
to get into systems through people. They are getting more savvy with phishing emails and their
use of social engineering. They are masters at tricking people into giving up their login and
passwords. Don’t fall for the trick. If you get an email asking you to click on a link or asking
you to enter your login information, hover over the link to make sure that it is a uvm.edu
address. For more information, visit the IT website – CLICK HERE.

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25
fiscal compliance & asset management 25
25
 conflicts of interest and
conflicts of commitment
If you, or a member of your immediate family, has (or could have) a personal or financial interest that affects independent judgment as it relates to
University duties OR it could result in personal gain or advancement at the expense of the University, you may have a conflict of interest. If you
engage in activities outside of the University that interfere with your ability to do your job at UVM or it is reasonably expected that it will interfere
with your ability to do your job at UVM, you may have a conflict of commitment. In both cases, the agreement, arrangement or activity could be
prohibited.

Special
Special Cases:
Cases: Gifts
Gifts and
and Gratuities
Gratuities
WHAT
WHAT IS
IS A
A CONFLICT?
CONFLICT?
While
While all
all UVM
UVM personnel
personnel are
are subject
subject to to conflicts
conflicts of
of interest,
interest, only
only
A
A conflict
conflict of
of interest
interest is
is an
an activity
activity that
that compromises
compromises or
or appears
appears to
to compromise
compromise University
University officials
officials who
who have
have authority
authority andand responsibility
responsibility with
with respect
respect
an
an employee’s
employee’s judgement
judgement in in performing
performing thethe employee’s
employee’s job
job duties.
duties. to
to specific
specific commercial
commercial contracts,
contracts, such
such as as those
those with
with service
service or
or product
product
WHAT vendors,
vendors, are
are required
required to
to comply
comply with
with the
the gift
gift and
and gratuity
gratuity provision.
provision.
WHAT SHOULD
SHOULD II DO
DO IF
IF II THINK
THINK II HAVE
HAVE A
A CONFLICT?
CONFLICT?
University
University officials
officials are
are prohibited
prohibited from
from giving,
giving, offering,
offering, asking
asking for,
for, or
or
If
If you
you are
are unsure
unsure of
of whether
whether anan activity
activity poses
poses aa conflict,
conflict, itit is
is best
best to
to err
err on
on the
the accepting
accepting for
for personal
personal use,
use, any
any gift
gift or
or gratuity
gratuity from
from that
that vendor.
vendor.
side
side of
of over
over disclosure
disclosure and
and report
report itit to
to your
your supervisor.
supervisor. While
While some some conflicts
conflicts
There
There are
are exceptions
exceptions for
for items
items of
of nominal
nominal value
value and
and certain
certain
are
are prohibited,
prohibited, most
most can
can be
be managed
managed via via aa written
written management
management plan. plan. Certain
Certain circumstances.
circumstances. Check
Check the
the Conflicts
Conflicts of
of Interest
Interest and
and Conflicts
Conflicts of
of
employees,
employees, such
such as
as officers
officers of
of administration
administration are are required
required to to file
file an
an annual
annual Commitment
Commitment Policy
Policy for
for more
more examples.
examples.
disclosure
disclosure statement
statement for
for potential
potential conflicts.
conflicts.

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26
fiscal compliance & asset management 26
26
 conflicts of interest and
conflicts of commitment
Examples
Examples of
of potential
potential general
general conflicts:
conflicts: Examples
Examples of of potential
potential
•• You
You hire
hire your
your uncle
uncle for
for aa job
job in
in your
your department
department even
even though
though he
he doesn’t
doesn’t have
have the
the required
required experience.
experience. research/scholarly
research/scholarly activity
activity
•• You
You enter
enter into
into aa contract
contract with
with your
your daughter’s
daughter’s company
company that
that is
is valued
valued more
more than
than what
what the
the contract
contract is
is worth.
worth. financial
financial conflicts:
conflicts:
•• You •• You
You have
have an
an ownership
ownership interest
interest in
in
You are
are looking
looking for
for aa vendor
vendor and and get
get three
three quotes
quotes from
from different
different companies.
companies. One
One ofof the
the vendors
vendors approaches
approaches you
you
and
and offers
offers you
you $500
$500 cash
cash ifif you
you choose
choose them.
them. You
You take
take the
the money
money and
and choose
choose this
this vendor.
vendor. aa company.
company. YouYou purchase
purchase
equipment
equipment andand supplies
supplies from
from your
your
•• You
You have
have aa student
student employee
employee in
in your
your department
department who
who hears
hears that
that you
you need
need someone
someone to
to help
help you
you with
with yardwork
yardwork at
at
your own
own company
company without
without doing
doing any
any
your house.
house. The
The student
student approaches
approaches you
you and
and offers
offers to
to do
do this
this work.
work. You
You submit
submit extra
extra time
time through
through the
the University
University
payroll sort
sort of
of comparative
comparative analysis
analysis of
of
payroll for
for hours
hours worked
worked doing
doing yardwork
yardwork at
at your
your house.
house.
more
more cost-effective
cost-effective options.
options.
•• You
You have
have developed
developed aa personal
personal relationship
relationship with
with someone
someone in
in your
your department.
department. You
You allow
allow that
that person
person to
to take
take extra
extra
•• You
You provide
provide consulting
consulting services
services toto
days
days off
off without
without submitting
submitting sick,
sick, vacation
vacation or
or personal
personal hours.
hours.
an
an organization
organization that
that also
also
•• You
You take
take on
on aa side
side job
job that
that interferes
interferes with
with your
your UVM
UVM job.
job. You
You cancel
cancel classes
classes and
and prioritize
prioritize the
the side
side job
job but
but continue
continue sponsors
sponsors your
your research.
research.
to
to get
get paid
paid through
through UVM
UVM as as though
though you
you are
are carrying
carrying the
the required
required course
course load.
load.

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27
fiscal compliance & asset management 27
27
 protecting university assets and Examples
Examples

appropriate use of resources

•• Creating
Creating aa phony
phony position
position in
in your
your
department
department and collecting a salary as
and collecting a salary as
though
though this
this were
were aa real
real person
person working.
working.
We all have a responsibility to make sure that University resources are not wasted or This
This is
is referred
referred to
to as
as aa “ghost
“ghost position”
position”
used inappropriately. Stealing, committing fraud, bribing, and providing kickbacks are and
and is
is fraud.
fraud.
all examples of inappropriate use of University resources and are all violations of the law, •• Using
Using University
University computers,
computers, copiers,
copiers, fax
fax
University policy, this Code or some combination of all three. We must all do our part to machines,
machines, and/or
and/or office
office supplies
supplies for
for your
your
protect University resources. personal
personal business.
business.

accuracy in recordkeeping Examples

Examples
•• Providing
Providing false
false information
information on on aa job
job
application.
application.
The University has an obligation to ensure the trust of the public and other stakeholders •• Taking
Taking the
the maximum
maximum daily
daily travel
travel meal
meal
through its financial and regulatory reporting. This includes making sure that the records allowance
allowance without
without incurring
incurring thethe full
full
and reports that you are responsible for filling out are accurate and are finished on expense.
expense.
time.
•• Submitting
Submitting extra
extra hours
hours on
on aa timesheet
timesheet even
even
Submitting false information on a timesheet or expense report is stealing. If you know though
though you
you didn’t
didn’t work
work that
that many
many hours.
hours.
that information included in a report is false and that report goes to the government, Submitting
Submitting false
false information
information on on aa timesheet
timesheet
that is fraud. It is important for all of us to be honest and truthful whenever we fill out is no different than stealing.
is no different than stealing.
records as part of our work duties.

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28
fiscal compliance & asset management 28
28
 relationships with university vendors and other third
parties in business transactions
Personnel are expected to deal fairly with vendors and other third parties
that UVM conducts business with. No unfair advantage shall be taken of
prospective or current vendors through manipulation, concealment, abuse
of privileged information, misrepresentation of material fact or any other
unfair practice. Additionally, all procurement policies and guidance must
be followed to provide for a fair, impartial and inclusive selection process.

Examples
Examples
•• Entering
Entering into
into an
an agreement
agreement with
with aa vendor
vendor even
even though
though you
you do
do not
not have
have authority
authority toto do
do so.
so.
•• Signing
Signing aa contract
contract without
without going
going through
through the
the procurement
procurement processes
processes for
for obtaining
obtaining andand
evaluating vendor quotes and proposals.
evaluating vendor quotes and proposals.
•• Withholding
Withholding oror reducing
reducing payments
payments to to aa contractor
contractor even
even though
though the
the contractor
contractor performed
performed
services
services according
according toto the
the agreement.
agreement.
•• Using
Using information
information provided
provided byby aa consultant
consultant without
without authorization
authorization and
and sharing
sharing itit as
as though
though itit
were
were your
your own
own work
work product.
product.

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29
fiscal compliance & asset management 29
29
principles
principles &
& standards
standards #3
#3
research

“Research
“Research is
is creating
creating new
new knowledge.”
knowledge.”

-Neil
-Neil Armstrong,
Armstrong, Astronaut
Astronaut (1930-2012)
(1930-2012)

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30
 research:
regulation & risk
At UVM, the scope of research is broad and diverse. While
research activities are an integral part of the University, it is
also an area that is heavily regulated and, as such, poses significant compliance risks. Ethics are fundamental to all academic research.
Without ethics and trust, a complex, modern research institution cannot function. Researchers must be aware of the ethical standards
governing their discipline and to avoid even the appearance of impropriety.

human subjects, vertebrate

animals & biohazard materials
Research involving human subjects, vertebrate animals or biohazardous materials involves
strict oversight by the institutional review board (IRB) or other oversight committee
assigned to assure compliance with federal rules.

The Research Protections Office provides oversight and support to these review boards and committees and the research they oversee.
More information regarding these protections is on the Research Protections Office website.
CLICK HERE.
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31
research 31
31
 responsible management of government funds
The government has increased its enforcement over effort management and reporting and has imposed multimillion-dollar fines on several universities.
Effort reporting requires that employees accurately report the percentage of the effort they spend working on federally sponsored research. Taxpayers,
like you, fund this research; the public should be confident that their tax dollars are spent as intended. UVM’s effort management and reporting training
tutorial can be found by CLICKING HERE.

Under
Under both
both university
university policy
policy and
and under
under various
various agreements
agreements andand contracts,
contracts, the
the University
University promises
promises that
that itit will
will strictly
strictly comply
comply with
with government
government grants
grants and
and contracts
contracts terms
terms and
and
conditions
conditions and
and expects
expects its
its personnel
personnel to
to be
be knowledgeable
knowledgeable about,
about, and
and comply
comply with,
with, such
such terms
terms and
and conditions
conditions as as appropriate
appropriate to,
to, and
and required
required by,
by, the
the nature
nature of
of their
their duties.
duties.
Applicable
Applicable federal
federal guidance
guidance requires
requires institutions
institutions of
of higher
higher education
education that
that receive
receive grants
grants or
or other
other federal
federal funding
funding to
to comply
comply with
with the
the regulations
regulations and
and guidelines.
guidelines.

export controls UVM

UVM personnel
personnel involved
involved inin research
research activities
activities at
at any
any level
level are
are strongly
strongly encouraged
encouraged
to
to enroll
enroll in
in the
the export
export compliance
compliance modules
modules provided
provided through
through the
the Collaborative
Collaborative
Institutional
Institutional Training
Training Initiative
Initiative (CITI)
(CITI) Program.
Program. Through
Through CITI,
CITI, in-depth
in-depth training
training
The government oversees the export of certain items, software,
regarding export controls is available to UVM personnel. This site
regarding export controls is available to UVM personnel. This site also provides also provides
technology and services. Determining whether the item or transaction
Responsible
Responsible Conduct
Conduct of of Research
Research training
training that
that isis helpful,
helpful, and
and sometimes
sometimes required,
required,
is subject to export controls requires some time and effort. However,
while the regulations are complex, there are some tools available to of
of those
those engaged
engaged in in Federally-sponsored
Federally-sponsored research.
research. Visit
Visit the
the SPA
SPAwebsite
website for
for more
more
help make the process easier. If you have any questions, you should information.
information. CLICK
CLICK HERE HERE
contact Sponsored Project Administration at (802) 656-3360.

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32
research 32
32
 principles
principles &
& standards
standards #4
#4
freedom of expression

“You
“You know
know life
life is
is all
all about
about
expression.
expression. You
You only
only live
live once,
once, and
and
you're not coming back so express
you're not coming back so express
yourself.”
yourself.”

Salt
Salt -n-
-n- Pepa,
Pepa, “Expression”,
“Expression”, Black’s
Black’s
Magic,
Magic, Next
Next Plateau
Plateau Records
Records (1989).
(1989).

page
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33
 mission & expectations
While our mission is dedicated to free expression and facilitation of the exchange of
ideas, we need to balance that with our need to ensure that University endorsement
is not improperly attributed and that University resources and facilities are used in
a manner consistent with policy and campus safety.

To this end, the UVM name, logo, seal, letterhead and other indicia of institutional
affiliation (otherwise known as “symbols”) are designed to advance the mission and
reputation of the University in a manner that reflects its
history and purpose and to strengthen and define its
identity and name recognition. Consistency in the use
of these symbols is critical to UVM’s identity and
reputation.
Improper or
Example
Example
unauthorized use
is prohibited and •• Setting
Setting up
up aa Facebook
Facebook account
account
to look like it is officially
to look like it is officially
could violate
sanctioned
sanctioned by by thethe University
University
state and/or when,
when, in
in fact,
fact, itit is
is not.
not.
federal law.

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34
freedom of expression 34
34
 campus speakers, political
activity & solicitation

campus If you are inviting a speaker, regardless of whether it is a paid engagement or

speakers not, you need to follow the procedures outlined in University policy.

As a tax-exempt organization, UVM has to comply with IRS regulations related to political activities. The University
political cannot participate in a political campaign. Similarly, personnel including officials, administrators, faculty and staff, in
activity their official capacity, cannot make statements related to a campaign in any manner. Contact University Relations at
(802) 656-5690 with questions.

We have a need to protect public safety and to enforce rules and regulations related to the use of campus grounds and
solicitation facilities. Anyone wishing to use University space or facilities must contact the University Event Services at (802) 656-
5665.

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35
freedom of expression 35
35
conclusion

“Continuous
“Continuous improvement
improvement is
is better
better
than
than delayed
delayed perfection.”
perfection.”

-Mark
-Mark Twain,
Twain, Writer,
Writer, Entrepreneur,
Entrepreneur,
Publisher
Publisher and Lecturer (1835
and Lecturer (1835 ––
1910)
1910)

page
page || 36
36
 resources
(click on any link to access the full document)

While the Office of Compliance Services oversees the University’s compliance

program, there are other offices and individuals that can provide guidance when
faced with a difficult decision or situation.

• Faculty Senate
• Human Resources Services
• Office of Audit Services
• Office of General Counsel
• Office of the Vice President of Executive Operations

In addition to these resources, the University also offers these resources depending on the issue or your needs. Click on any resource for more
information.

•• Affirmative
AffirmativeAction
Action && Equal
Equal Opportunity
Opportunity (AAEO)
(AAEO) Office
Office of
of the
the Vice
Vice President
President for
for Human
Human Resources,
Resources, Diversity
Diversity and
and Multicultural
MulticulturalAffai
Affai
•• Disability
Disability Certification
Certification and
and Support
Support rs
rs
•• Office
Office of
of International
International Education
Education Diversity
Diversity and
and Equity
Equity Unit
Unit
•• Risk
Risk Management & Safety
Management & Safety Student
Student Financial
Financial Services
Services
•• Sponsored
Sponsored Project
ProjectAdministration
Administration (SPA)
(SPA) University
University Financial
Financial Services
Services

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37
conclusion 37
37
 policy references, related documents
& links
Your Code of Conduct and Ethical
Standards references several University
policies and University Operating
Procedures, or UOPs, that provide more
information related to these risk areas. In
addition, the Code lists out related
documents and links that provide
additional guidance. Personnel should
refer to the Code for a complete list of
policies, procedures, documents and links.

page
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38
conclusion 38
38
 contacts
CONTACT
CONTACT INFORMATION
INFORMATION FOR
FOR CLARIFICATION
CLARIFICATION ON
ON THE
THE CODE
CODE
Tessa
Tessa Lucey,
Lucey, Director
Director of
of Compliance
Compliance Services,
Services, Office
Office of
of Audit
Audit &
& Compliance
Compliance Services
Services
(801)
(801) 656-0847
656-0847
Tessa.Lucey@uvm.edu
Tessa.Lucey@uvm.edu
Compliance@uvm.edu
Compliance@uvm.edu
Billings
Billings Library,
Library, B159
B159
48
48 University
University Place,
Place, Burlington,
Burlington, VT
VT 05405
05405

ETHICS
ETHICS AND
AND COMPLIANCE
COMPLIANCE
REPORTING
REPORTING && HELPLINE
HELPLINE

877-310-0413
OR
OR
click
click here:
here:

page
page || 39
39
conclusion 39
39
 appendix (click on any link for additional information)

HEALTH, SAFETY & CAMPUS ENVIRONMENT

CREATING
CREATING A
A RESPECTFUL
RESPECTFUL CAMPUS
CAMPUS ENVIRONMENT
ENVIRONMENT
•• Our
Our Common
Common Ground
Ground
•• Diversity
Diversity Statement
Statement
•• Equal
Equal Employment
Employment Opportunity/Affirmative
Opportunity/Affirmative Action
Action Policy
Policy Statement
Statement
•• Equal
Equal Opportunity
Opportunity in
in Educational
Educational Programs
Programs and
and Activities
Activities and
and Non-Harassment
Non-Harassment
•• Sexual
Sexual Misconduct
Misconduct and
and Harassment
Harassment
•• Disability
Disability Accommodations
Accommodations for
for Employees
Employees and
and Applicants
Applicants for
for Employment
Employment
•• Amorous
Amorous Relationships
Relationships with
with Students
Students
•• Amorous
Amorous Relationships
Relationships –– Department
Department of
of Athletics
Athletics
CREATING
CREATING A
A SAFE
SAFE AND
AND HEALTHY
HEALTHY CAMPUS
CAMPUS –– PERSONAL
PERSONAL SAFETY
SAFETY
•• Alcohol
Alcohol Policy
Policy –– Faculty
Faculty and
and Staff
Staff
•• Campus
Campus Safety
Safety and
and Security:
Security: Clery
Clery Act
Act
•• Campus
Campus Security
Security Authorities
Authorities (CSA)
(CSA) –– Designation
Designation of
of and
and Reporting
Reporting By
By

page
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40
conclusion 40
40
 appendix (click on any link for additional information)

HEALTH, SAFETY & CAMPUS ENVIRONMENT

CREATING
CREATING A
A SAFE
SAFE AND
AND HEALTHY
HEALTHY CAMPUS
CAMPUS –– PERSONAL
PERSONAL SAFETY
SAFETY (CONTINUED)
(CONTINUED)
•• Drug
Drug Free
Free Workplace
Workplace
•• Personal
Personal Safety
Safety and
and Security
Security
•• Sexual
Sexual Harassment
Harassment and
and Misconduct
Misconduct
•• Weapons
Weapons and
and Explosives
Explosives
•• Minors
Minors in
in the
the Lab
Lab
•• Protection
Protection of
of Minors
Minors
•• Minors;
Minors; Reporting
Reporting of
of Abuse
Abuse or
or Neglect
Neglect of
of and
and Crimes
Crimes
CREATING
CREATING A
A SAFE
SAFE AND
AND HEALTHY
HEALTHY CAMPUS
CAMPUS –– ENVIRONMENTAL
ENVIRONMENTAL SAFETY
SAFETY
•• Emergency
Emergency Management
Management
•• Fire
Fire Safety
Safety
•• Laboratory
Laboratory Health
Health and
and Safety
Safety

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41
conclusion 41
41
 appendix (click on any link for additional information)

FISCAL COMPLIANCE & ASSET MANAGEMENT

PRIVACY
PRIVACY AND
AND SECURITY
SECURITY OF
OF CONFIDENTIAL
CONFIDENTIAL INFORMATION
INFORMATION
•• Privacy
Privacy
•• FERPA
FERPA Rights
Rights Disclosure
Disclosure
•• Data
Data Breach
Breach Notification
Notification Policy
Policy
•• Records
Records and
and Document
Document Requests
Requests
•• Records
Records Retention
Retention
•• Information
Information Security
Security
•• Computer,
Computer, Communication,
Communication, and
and Network
Network Technology
Technology Acceptable
Acceptable Use
Use

CONFLICTS
CONFLICTS OF
OF INTEREST
INTEREST AND
AND CONFLICTS
CONFLICTS OF
OF COMMITTMENT
COMMITTMENT
•• Conflict
Conflict of
of Interest
Interest and
and Commitment
Commitment
•• Financial
Financial Conflict
Conflict of
of Interest
Interest in
in Sponsored
Sponsored Research
Research

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42
conclusion 42
42
 appendix (click on any link for additional information)

FISCAL COMPLIANCE & ASSET MANAGEMENT

PROTECTING
PROTECTING UNIVERSITY
UNIVERSITY ASSETS
ASSETS AND
AND APPROPRIATE
APPROPRIATE USE
USE OF
OF RESOURCES
RESOURCES
•• Procurement
Procurement or
or Lease
Lease of
of Goods
Goods and
and Services
Services and
and Contract
Contract Approval
Approval and
and Signatory
Signatory Authority
Authority for
for Procurement
Procurement or
or Lease
Lease of
of Goods
Goods an
an
dd Services
Services
•• Computer,
Computer, Communication,
Communication, and
and Network
Network Technology
Technology Acceptable
Acceptable Use
Use
•• Business
Business Meals,
Meals, Hospitality,
Hospitality, and
and Amenity
Amenity
•• Travel
Travel
•• Contract
Contract Approval
Approval and
and Signatory
Signatory Authority
Authority
•• Facilities
Facilities and
and Grounds
Grounds Use
Use
ACCURACY
ACCURACY IN
IN RECORDKEEPING
RECORDKEEPING
•• Records
Records Retention
Retention
•• Effort
Effort Management
Management and
and Reporting
Reporting on
on Sponsored
Sponsored Agreements
Agreements

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43
conclusion 43
43
 appendix (click on any link for additional information)

FISCAL COMPLIANCE & ASSET MANAGEMENT

ACCURACY
ACCURACY IN
IN RECORDKEEPING
RECORDKEEPING (CONTINUED)
(CONTINUED)
•• Travel
Travel
•• Business
Business Meal,
Meal, Hospitality
Hospitality and
and Amenity
Amenity
•• Export
Export Controls
Controls
•• Movable
Movable Equipment
Equipment
•• I-9
I-9
RELATIONSHIPS
RELATIONSHIPS WITH
WITH UNIVERSITY
UNIVERSITY VENDORS
VENDORS AND
AND OTHER
OTHER THIRD
THIRD
PARTIES
PARTIES IN
IN BUSINESS
BUSINESS TRANSACTIONS
TRANSACTIONS
•• Affiliated
Affiliated Organizations
Organizations
•• Procurement
Procurement or
or Lease
Lease of
of Goods
Goods and
and Services
Services and
and Contract
Contract Approval
Approval and
and Signatory
Signatory Authority
Authority for
for Procurement
Procurement or
or Lease
Lease of
of Goods
Goods and
and Servi
Servi
ces
ces

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44
conclusion 44
44
 appendix (click on any link for additional information)

RESEARCH
REGULATION
REGULATION AND
AND RISK
RISK
•• Copyright
Copyright
•• Cost
Cost Transfers
Transfers Involving
Involving Sponsored
Sponsored Agreements
Agreements
•• Effort
Effort Management
Management and
and Reporting
Reporting on
on Sponsored
Sponsored Agreements
Agreements
•• Establishment
Establishment ofof Advance
Advance Accounts
Accounts for
for Sponsored
Sponsored Agreements
Agreements
•• Export
Export Controls
Controls
•• Intellectual
Intellectual Property
Property
•• Issuing
Issuing and
and Monitoring
Monitoring Subawards
Subawards onon Sponsored
Sponsored Agreements
Agreements
•• Misconduct
Misconduct in
in Research
Research and
and Other
Other Scholarly
Scholarly Activities
Activities
•• Moveable
Moveable Equipment
Equipment
•• Residual
Residual Balances
Balances on
on Sponsored
Sponsored Agreements
Agreements
•• Use
Use of
of University
University Research
Research Facilities
Facilities and
and Equipment
Equipment by
by External
External Users
Users

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45
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45
 appendix (click on any link for additional information)

FREEDOM OF EXPRESSION
MISSION
MISSION AND
AND EXPECTATIONS
EXPECTATIONS
•• Campus
Campus Speakers
Speakers
•• Copyright
Copyright
•• Political
Political Activities:
Activities: Tax
Tax Exempt
Exempt Organization
Organization Restrictions
Restrictions
•• Solicitation
Solicitation
•• Trademarks
Trademarks
•• University
University Name,
Name, Symbols,
Symbols, Letterhead
Letterhead and
and Other
Other Proprietary
Proprietary Indicia
Indicia of
of Affiliation
Affiliation
•• University
University Sponsored
Sponsored Social
Social Media
Media

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46
conclusion 46
46
 related documents & more links (click on any link
for additional information)

Employee Handbooks and Collective Bargaining Agreements

Statement of Commitment and Expectations In The Workplace

UVM Institutional Policy Website

HelpLine FAQ’s

Why Diversity Statement

Effort Management Tutorial

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47
conclusion 47
47
the
end
thank
thank you
you

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