Office of University Compliance

University Policy on Policies

Posted on April 7, 2022August 8, 2024 by Andujar, Omar

Guideline: Recommended guidance or additional information used to support policies and procedures, industry best practice, or intended to educate the workforce on how to achieve a desired outcome. Allows end-user discretion in interpretation, implementation, or use. Non-compliance with, or violation of, guidelines does not create the same level of risk.

Policy Owner: The unit, senior institutional official and/or designee responsible for authoring, implementing, maintaining, and monitoring a policy.

University Senior Policy Council: The University Senior Policy Council is a standing committee whose role is to review and approve new and revised University policies. The Senior Policy Council is comprised of the University President; Executive Secretary to the Board of Trustees; Chief of Staff; General Counsel; Chief Compliance Officer, Chief Human Resources Officer, Provost, and the Vice President for Finance and Chief Financial Officer. Others may be invited, as necessary.

Procedures: Operational processes established for the implementation of policies. If a policy is “what” the institution does, its procedures are “how” it carries out the requirements of a policy. Non-compliance with, or violation of, procedures may result in disciplinary action.
Procedures

outline required actions by objective and/or job function;
state clearly and succinctly the step-by-step instructions that must be followed to implement policy effectively;
specify the structure to enforce the policy;
University Policy procedures shall not be revised without consultation with the Office of University Compliance.

Revision, Editorial: Includes modifications related to spelling, grammar, format, and updates to hyperlinks or URLs, contact information, references, titles of individuals and organizations.

Revision, Non-substantive: Includes modifications intended to enhance clarity without changing the intent of the policy, such as adding or modifying definitions, rearranging or re-wording sentences without changing their meaning or the policy’s requirements for compliance.

Revision, Substantive: Includes significant modifications to the nature and/or scope of the policy that affect its requirements, principles, or intent.

Senior Institutional Official (SIO): The appropriate University officer (Vice President, Vice Provost, or similar) who has authority and responsibility for the area or activity to which a policy may apply.

Stakeholder: University members with expertise in the subject matter of the policy, or whose operations will be significantly affected by the policy.

University Policy: An official statement expressing the position of the University on an issue of university-wide importance. A university policy

is a governing principle that mandates or constrains actions, establishes rights or obligations, or guides the decisions and actions of the University;
has broad application;
exists to achieve compliance with applicable laws, regulations, and organizational requirements; to promote operational efficiencies; to enhance the University’s mission; to reduce institutional risk; and/or to promote ethical standards, integrity and accountability;
is approved by the administrative authority of the University and/or the Board of Trustees

Policies that do not fit the criteria of a University Policy, such as individual unit policies, should be vetted through the appropriate Dean or Director for approval to ensure consistent application and to avoid conflict with any University or unit policies. Unit policies, procedures and guidelines shall not subvert, supersede, or contradict University Policies. Units should use a similar policy review process as outlined in this document. Please contact the Office of University Compliance or refer to the Policy website for assistance.

All University Policies shall be developed, approved, revised, and decommissioned in accordance with the procedures outlined in this Policy. In rare circumstances, exceptions to this process may be approved by the President in consultation with the University Senior Policy Council and notification to the Board of Trustees as may be warranted.

Individual units (e.g., colleges, schools, centers, institutes, departments) may create, communicate, maintain, and enforce policies that are applicable to their respective authority, as long as these are not in conflict with official University Policies.

I. New University Policy
II. Revising a University Policy
III. Decommissioning a University Policy
IV. Archiving University Policy
V. Expedited (Emergency) Policy Approvals

I. New University Policy

1. Determine Need

University Policies should only be created when they define University values, institutional objectives or mandates; address federal or state law, regulations, or rules; or manage potential risk or liability.
Any individual or unit may identify the need for a new University Policy. However, a Senior Institutional Official, in consultation with the Office of University Compliance, must confirm the need for the policy considering

- whether the proposed policy meets the criteria of a University Policy as defined;
- if an alternative such as workforce guidance or procedures is the most effective and efficient approach;
- if existing University policy addresses or resolves the identified need;
- implications of the policy including risks and costs (i.e., will adoption of the proposed policy require new resources or reassignment of existing resources?)

2. Development

If a proposed policy involves matters within the purview of more than one senior institutional official, they will ensure consultation and coordination among appropriate leadership.
The Senior Institutional Official may assign the development and administration of the policy to a responsible office or individual (Policy Owner).
The Policy Owner is responsible for developing a draft policy in consultation with key stakeholders and University governance groups (e.g., University Senate, Deans Council). It is advisable that the Policy Owner convene a stakeholder policy development group to provide initial vetting of the proposed policy.
University policy

- must follow the Policy Template [link];
- should be written so that it is clear and concise with sufficient information on the subject without being excessive in length or complexity;

3. Engage the Office of University Compliance

Early in the development stages, the individuals or groups developing the policy must notify the Office of University Compliance.
University Compliance is responsible for

- stewardship of the policy development process to ensure consistency with existing policies, language, clarity, format and appropriate vetting and approval;
- engaging the Office of the General Counsel as appropriate;
- reviewing stakeholder and partner input;

4. Approval

Although the development or administration of a policy may be delegated, the SIO is responsible for ensuring all necessary approvals are obtained.
Once the SIO is satisfied with the final policy draft, it must be forwarded along with a list of stakeholder reviewers to University Compliance at policy@uconn.edu. University Compliance may consult with the Office of General Counsel for final review.
For policies that apply to the Storrs, Regional and UConn Health campuses, University Compliance will coordinate review and approvals with the appropriate UConn Health policy committees before advancing the policy to the Office of the President.
University Compliance will work with the Office of the President and the SIO to present the draft policy to the University Senior Policy Council for their review and recommendation to the President. There may be occasions when a University Policy requires review and approval by the Board of Trustees prior to adoption.
The President, in consultation with the Senior Policy Council, will make the final determination regarding when a University Policy shall be presented to the Board of Trustees for approval. If so, the proposed policy will typically be assigned to one or more standing Board committees to review and approve before the proposed policy goes to the full Board for final approval.
University Policies that advance to the Board for approval are often those that relate to:

- University governance and describe the composition, powers, and duties of the Board of Trustees, the President, or University Senate;
- University By-Laws (e.g., academic appointment and tenure; grievances; leaves of absence; naming of facilities; intellectual property; the establishment of new regional campuses,
  schools or colleges; expressions of dissent; and student residency);
- Code of Conduct;
- high-level university financial operations such as investments and the establishment of, or significant changes in existing, major University fiscal policies (e.g., capital expenditures).

5. Publication & Notification

Once the University Policy has been approved, the SIO will collaborate with University Compliance to ensure the policy is posted to policy.uconn.edu (and health.uconn.edu/policies where
applicable.
The SIO shall oversee the communication, implementation, training, administration, and maintenance of the University Policies within their purview. The SIO must publicize and distribute the policy to the University community members to whom it applies and to offices with implementation requirements.
Policies published to the University’s Policy site are the official and current versions.
Members of the University community are responsible for familiarizing themselves and complying with University Policies.
All new University Policies not requiring Board approval shall be shared with the Board of Trustees at the next regularly scheduled meeting as an informational item.

II. Revising a University Policy

Regularly reviewing policies and procedures ensures that the University’s operations and administration are

in compliance with new laws and regulations;
current with new systems or technology;
consistent with best practices.

1. Review

Policies must be reviewed at least once every three (3) years, or sooner if legal or regulatory requirements or changes in operational processes deem necessary. The senior institutional official,
or designee, must ensure the periodic review and revision of policies related to their areas of responsibility.
University Compliance monitors policies for compliance with the required review schedule.
The senior institutional official must notify University Compliance at policy@uconn.edu
- of necessary changes by providing a strikethrough or “redline” copy of the policy with proposed revisions;
  OR
- if review was conducted and there are no necessary changes.
The date of review, even in the absence of revision, shall be noted in the Policy History of the document.

2. Revision Approvals

University Compliance, in conjunction with the senior institutional official, will determine if the proposed revisions are editorial, non-substantive or substantive.

Editorial revisions will be completed by University Compliance.
Non-substantive revisions will be completed by University Compliance after notifying the University Senior Policy Council.
Substantive revisions must follow the same review and approval process as a new policy.

III. Decommissioning a University Policy

When a policy is no longer needed or is more effectively combined with another policy, the responsible office will submit a formal request to the senior institutional official responsible for the policy. The senior institutional official shall confer with applicable University governance groups and subject matter experts as appropriate to ensure overall impact is considered. The senior institutional official will collaborate with University Compliance to seek formal decommissioning approvals. If there is disagreement as to whether a policy should be decommissioned, the University Senior Policy Council will decide.

University Compliance will remove decommissioned policies from the policy.uconn.edu website and inform the Senior Policy Council quarterly of decommissioned policies.

IV. Archiving a University Policy

University Compliance will work with University Archives to properly maintain the record. Policy Owners are strongly encouraged to retain policy records.

V. Expedited (Emergency) Policy Approvals

The expedited policy approval process is reserved for policies that the President or the Senior Policy Council deem crucial for the health and safety of the University community, the continuity of University operations, to address legal requirements or significant institutional risk and, therefore, must be processed in a shorter time than possible through the established approval process.

In such cases,

the President or the Board of Trustees identifies an emergency policy need and assigns a senior institutional official;
the stakeholder review process may be bypassed, but the draft policy must be reviewed by the Senior Policy Council;
the Senior Policy Council shall consider any immediate and significant impact on operations;
emergency policies that apply to UConn Health shall be provided to the appropriate policy committees for expedited review and approval.

Unless a duration is specified in the Expedited Policy, all Expedited Policies will be reviewed in one (1) year by the Senior Policy Council to determine whether the policy should be extended, made permanent, or decommissioned.

Use of Students in Outside Employment

Posted on June 2, 2011August 18, 2023 by Fearney, Kimberly

Title:	Use of Students in Outside Employment
Policy Owner:	Office of University Compliance
Applies to:	Faculty, Staff
Campus Applicability:	All Campuses, including UConn Health
Effective Date:	July 14, 2015
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530
Official Website:	https://compliance.uconn.edu/

Background and Reasons for the Policy: The Code of Ethics for Public Officials preclude public employees from accepting other employment which will impair the employee’s independence of judgment or otherwise create a conflict of interest.

Purpose of Policy: To provide guidance on the employment of students by faculty and staff for work external to the University.

Expected Institutional Outcome: Compliance with the Code of Ethics.

Applicability of Policy: All employees.

Policy Statement: Pursuant to Connecticut General Statute Section 1-84(b) of the Code of Ethics for Public Officials, a state employee may not accept other employment which will impair his/her independence of judgment as to his/her official duties or employment. Furthermore, in accordance with Connecticut General Statute Section 1-86 and the Regulations of Connecticut State Agencies Section 1-81-29, a state employee with a potential conflict of interest must inform his/her supervisor who shall assign the matter to another who is not subordinate to the individual with the conflict.

Potential conflicts may occur when a University employee hires a student in any non-University supported activity. Therefore, 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. Faculty members who wish to hire a graduate student and who teach a course in which the student is enrolled, serve as a member of the student’s thesis or dissertation committee, or serve as the student’s advisor or the director of his or her thesis or dissertation research must also receive written approval from the Dean of the Graduate School. The University requires that each student 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. In addition, the student should receive a fair market value rate of pay.

Students have on-going recourse to the Provost who will consult with the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students) in order to address any grievances that may arise during the term of the employment.

Failure to comply constitutes a violation of the State ethics code and University policy and is subject to disciplinary procedures of both.

Responsibilities: All employees.

Use of Students in Outside Employment Letter Template

History

Revised: 07/13/2015; 12/16/2014; 06/23/2008

New Policy: 03/01/2004

Non-Retaliation Policy

Posted on May 24, 2011May 28, 2024 by Fearney, Kimberly

Title:	Non-Retaliation Policy
Policy Owner:	Office of the President
Applies to:	Faculty, Staff, Students, Contractors and Affiliated Persons
Campus Applicability:	All Campuses, including UConn Health
Effective Date:	October 22, 2012
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530
Official Website:	http://president.uconn.edu/

PURPOSE

To define how the University provides for the protection of any person or group within its community from retaliation who, in good faith, participates in investigations or reports alleged violations of policies, laws, rules or regulations applicable to the University of Connecticut.

POLICY STATEMENT

The University encourages individuals to bring forward information and/or complaints about violations of state or federal law, University policy, rules, or regulations. Retaliation against any individual who, in good faith, reports and/or participates in the investigation of alleged violations, or who assists others in making such a report, is strictly forbidden. This policy does not protect an individual who knowingly files a report or provides information as part of an investigation that is false or is filed in bad faith. The University will take appropriate action, up to and including dismissal, against any employee, student, or affiliated person who violates this policy.

DEFINITIONS

Retaliation: Any adverse action taken, or threatened against an individual because they have, in good faith, reported an allegation concerning the violation of state or federal law, University policy, rule, or regulation, or because they have participated in any manner with an investigation of such an allegation, or in an effort to deter an individual from doing so.

Examples of actions that may constitute retaliation include, but are not limited to:

unsubstantiated adverse performance evaluations or disciplinary action;
adverse decisions relating to the terms or conditions of employment or education;
interference with or denial of promotion or advancement opportunities (whether employment-related or academic);
reduction in a student’s grade;
interference with or denial of participation in University programs or activities;
unfounded negative job references or interfering with one’s job search;
denial or removal of co-authorship on a publication;
repeated intimidation or humiliation, derogatory or insulting remarks, or social isolation which may occur indirectly or directly from co-workers and/or a supervisor;
physical threats and/or destruction of personal or state property

Any action taken or threatened that would dissuade a reasonable person from engaging in activities protected by this policy may also be considered retaliatory.

Good Faith Report: A report made with an honest and reasonable belief that a university-related violation of law or policy may have occurred.

Bad Faith Report: A report made that is knowingly false and/or made with malicious intent.

Protected Activities: Good faith reporting, whether internally or externally, or inquiring about suspected wrongful or unlawful activity; assisting others in making such a report; and/or participating in an investigation or proceeding related to suspected wrongful or unlawful activity.

REPORTING PROCESS

If an individual believes that they have been subjected to retaliation, they should either contact the office to which the initial complaint was filed or any of the following University offices:

Storrs & Regional Campuses	UConn Health
The Office of University Compliance 28 Professional Park, Unit 5084 Storrs, CT 06269-5084 Telephone: (860) 486-2530 Reportline: 1-888-685-2637Website: https://compliance.uconn.edu	The Office of University Compliance Administrative Services Building 263 Farmington Avenue Farmington, CT 06030-5329 Telephone: (860) 679-1969 Reportline: 1-888-685-2637Website: https://compliance.uconn.edu
The Office of Institutional Equity (OIE) 241 Glenbrook Road Wood Hall, Unit 4175 Storrs, CT 06269-4175 Telephone: (860) 486-2943 Email: equity@uconn.edu OIE’s Discrimination Complaint Procedures: https://equity.uconn.edu/policiesprocedures/	The Office of Institutional Equity (OIE) Munson Building 263 Farmington Avenue Farmington, CT 06030-5130 Telephone: (860) 679-3563 Fax: (860) 679-3805 Email: equity@uconn.edu OIE’s Discrimination Complaint Procedures: https://equity.uconn.edu/policiesprocedures/
Office of Faculty & Staff Labor Relations 9 Walters Avenue, Unit 5075 Storrs, CT 06269-5075 Telephone: (860) 486-5684 Website: https://lr.uconn.edu/	Employee/Labor Relations Munson Building 263 Farmington Avenue Farmington, CT 06030 – 4035 Telephone: 860-679-8067 Website: https://health.uconn.edu/human-resources/services/employee-labor-relations/
University of Connecticut Police Department 126 North Eagleville Road, Unit 3070 Storrs, CT 06269-3070 Telephone: (860) 486-4800 Website: https://publicsafety.uconn.edu/police/	University of Connecticut Police Department 263 Farmington Avenue Farmington, CT 06030 – 3925 Telephone: 860-486-4800 Website: https://publicsafety.uconn.edu/police

Any individual who is covered by a collective bargaining contract are also encouraged to contact their union:

Union	Contact Information
The American Association of University Professors (AAUP), University of Connecticut Chapter	Telephone: (860) 487-0450 Website: http://www.uconnaaup.org/contact/
The University of Connecticut Professional Employees Association (UCPEA)	Telephone: (860) 487-0850 Website: http://ucpea.ct.aft.org/
Maintenance and Service Unit, Connecticut Employees Union Independent (CEUI)	Telephone: (860) 344-0311 Website: http://ceui.org/
Administrative Clerical Unit – American Federation of State, County and Municipal Employees (AFSCME)	Telephone: (860) 224-4000 Website: https://www.afscme.org/
Connecticut Police and Fire Union	Telephone: (860) 953-2626 Website: https://cpfu.org/
Social and Human Services Unit – American Federation of State, County and Municipal Employees (AFSCME)	Telephone: (860) 224-4000 Website: https://www.afscme.org/
Administrative and Residual Employees Union (A&R)	Telephone: (860) 953-1316 Website: http://andr.ct.aft.org/
New England Health Care Employees Union – District 1199	Telephone: (860) 549-1199 Website: http://www.seiu1199ne.org/
University Health Professionals (UHP)	Telephone: (860) 676-8444 Website: http://uhp3837.ct.aft.org/

Nothing in this policy shall be deemed to diminish the rights, privileges or remedies of a University (State) employee under other federal or state law or under any collective bargaining agreement or employment contract.

ADDITIONAL RESOURCES

In addition to the resources above, the following offices may be helpful to University employees and students who believe they are experiencing retaliation.

Employee Assistant Program

Website: https://hr.uconn.edu/employee-assistance-program/

University Ombuds

Website: https://ombuds.uconn.edu/

Office of the Dean of Students

Website: https://dos.uconn.edu/

UConn Cultural Centers

Website: https://office.diversity.uconn.edu/cultural-centers/

Office for Diversity and Inclusion:

Website: https://diversity.uconn.edu/

POLICY HISTORY

Policy created: 09/22/2009

Revisions:

10/22/2012 (Non-substantive revisions)

05/03/2021 (Approved by President’s Cabinet)

Guide to the State Code of Ethics

Posted on May 24, 2011September 12, 2024 by Fearney, Kimberly

Title:	Guide to the State Code of Ethics
Policy Owner:	Office of University Compliance
Applies to:	Faculty, Staff
Campus Applicability:	All Campuses
Approval Date:	October 25, 2023
Effective Date:	October 25, 2023
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530 or universitycompliance@uconn.edu
Official Website:	https://compliance.uconn.edu

PURPOSE

Pursuant to state law, the University is required to adopt in cooperation with the Office of State Ethics, an ethics statement as it relates to the mission of the University. The Code of Ethics for Public Officials (the Code) sets forth principles of ethical conduct that all state employees, including employees of the University, must observe. All employees of the University are expected to become familiar with the Code and comply with all its provisions. This statement is intended to be a general guide to assist you in determining what conduct is prohibited so that it may be avoided. It is not intended to supersede the Code. Please note that under state statute, compliance with the Code is the responsibility of the employee, not the University.

The Office of State Ethics has jurisdiction to interpret and enforce the Code. Violations may result in a formal complaint proceeding filed against the employee and sanctions of up to $10,000 per violation. The entire Code and regulations, as well as a summary of these rules, may be found at the Office of State Ethics website. For formal and informal interpretations of the Code of Ethics, employees should contact the Office of State Ethics. In addition, the University must designate an Ethics Liaison as an information resource regarding compliance. An employee who has a question or is unsure about the provisions of this policy, or who would like assistance in contacting the Office of State Ethics, should contact the University’s Ethics Liaison.

The following general provisions of the Code are applicable to all employees of the University of Connecticut:

CONFLICT OF INTEREST

GIFTS: In general, employees are prohibited from accepting gifts, discounts or gratuities of any kind from prohibited donors: (1) doing business with or seeking to do business with the University; (2) directly regulated by the University; (3) known to be a registered lobbyist or a lobbyist’s representative, or; (4) pre-qualified under Conn. Gen. Stat. §4a-100. A list of registered lobbyists can be found on the web site of the Office of State Ethics. Certain items are excluded from the definition of “gift,” including: items offered to the public at large (for example, trinkets provided at an open house), items valued at under $10, food and beverage up to $50 in a calendar year from each donor and training for a product purchased by the University provided such training is offered to all customers of that vendor. “Gifts to the state” are also permitted as long as the gifts facilitate University actions or functions. If an employee is offered a benefit from someone other than the prohibited donors listed above, and the benefit is offered because of the employee’s position at the University, the total value of benefits received from one source in a year must not exceed $100. Additionally, supervisors may only accept gifts valued at no more than $100 from a subordinate; a subordinate may only accept gifts valued at no more than $100 from his/her supervisor. This provision not only applies to direct supervisors and subordinates, but to any individual up or down the chain of command. Questions regarding specific facts and circumstances surrounding various gift-giving scenarios should be directed to the University’s Ethics Liaison or the Office of State Ethics.
OUTSIDE EMPLOYMENT: No employee may accept outside employment that will impair their independence of judgment with regard to their state duties or would encourage the disclosure of confidential information gained in state service. Additionally, although an employee may use their expertise, they may not use their state position to obtain outside employment. An employee is not allowed to use their business address, telephone number, title or status in any way to promote, advertise or solicit personal business. Employees interested in pursuing outside employment may seek and receive written approval from their Supervisor and, if uncertain about the application of the Code, the Ethics Liaison or the Office of State Ethics. For faculty and professional staff, the University of Connecticut By-Laws specifically address consulting, private professional practice, teaching, and other outside employment situations. Faculty and members of the AAUP bargaining unit must adhere to the University’s Faculty Consulting policy as well as the policy on assigning textbooks which they have authored. Union members are referred to contract articles, if such exist, relating to outside employment in their respective collective bargaining agreements. If you are thinking about an opportunity for outside employment, you may also consult with the University’s Ethics Liaison for guidance.
FINANCIAL BENEFIT: Employees may not use their official position or confidential information gained in their service for personal financial benefit, or the financial benefit of a family member or a business with which they, or a family member, are associated. Employees are prohibited from using state time, personnel or materials, including telephones, computers, e-mail systems, fax machines, copy machines, state vehicles and any other supplies, for personal, non-state related purposes. It is understood, however, that incidental use of state property for personal use is permissible so long as you reimburse the state for any identifiable charges.
CONTRACTS WITH THE STATE: Employees, their immediate family members, and/or a business with which an employee or their family member is associated may not enter into a contract with the state valued at $100 or more, unless the contract has been awarded through an open and public process. The Code permits an exemption for contracts with a public institution of higher education to support a collaboration with such institution to develop and commercialize any invention or discovery. The Office of State Ethics has ruled that immediate family members may not be hired as an independent contractor unless there has been an open and public process.
APPEARANCE FEES: No employee may personally accept any fee or honorarium given in return for a speech or appearance made or article written in the employee’s official capacity. Employees may, however, direct that the fee or honorarium be deposited in a University account to be used for future University-related business activities.
NECESSARY EXPENSES/GIFTS TO THE STATE: payment or reimbursement of expenses to participate in a particular event may be acceptable under certain circumstances and, if received from a non-governmental entity, may also require a disclosure filing with the Office of State Ethics. “Necessary expenses" are limited to: necessary travel expenses, lodging for the nights before, of and after the appearance, speech, or event; meals and any related conference or seminar registration fees. “Gifts to the state” may also be acceptable to attend an event that is relevant to your state duties and do not require “active participation”.

POLITICAL ACTIVITY

Employees are not prohibited from seeking political office as long as it is not done on State time or with State equipment. However, any State employee who is elected to state political office may not be employed by two branches of state government simultaneously. Therefore, any employee who accepts an elective state office must resign or take a leave of absence from his/her position with the University. Consult the University By-Laws and inform your supervisor prior to participating in a political campaign.
No employee of the University will engage in partisan political activities while on state time. Additionally, no employee will use state materials or equipment for the purpose of influencing a political election of any sort.

MISCELLANEOUS: POST-EMPLOYMENT (REVOLVING DOOR) AND VENDOR NOTIFICATION

The State Code of Ethics contains several provisions regarding post-state employment. Prior to leaving employment with the University, all employees should review the applicable rules and, if necessary, seek guidance from the Ethics Liaison or The Office of State Ethics.

You may never use confidential information for financial gain for yourself or any other person. This is a lifetime prohibition. “Confidential Information” is any information not generally available to the public. The information may be in any form (written, photographic, recorded, computerized, etc.) including orally transmitted information, e.g., conversations, negotiations, etc.

You may not represent anyone concerning any particular matter in which you personally and substantially participated while in state service in which the state has a substantial interest.

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.

No official or employee shall counsel, authorize or otherwise sanction action that violates any provision of the Code of Ethics.

The provisions of this document shall apply to all employees of the University of Connecticut. All current and future employees of the University shall be supplied with a copy of this document, and it shall be the responsibility of each employee to be familiar with these provisions and to comply with them. It is strongly suggested that employees avoid those situations which may give the appearance of being a conflict of interest. When in doubt or unsure about these provisions, an employee should contact either his or her supervisor, department head, or the University’s Ethics Liaison. Ultimately, The Office of State Ethics is the authority that determines what conduct constitutes an ethics violation under the law. Therefore, you are strongly encouraged to discuss any situation which may pose a conflict of interest or other ethics problem with the Office’s staff attorneys.

The University will notify vendors/contractors doing business with it of these provisions through its procurement officers. A summary of the State Code of Ethics as it applies to vendors will also be provided. Copies of this policy will be provided upon request.

Please note: Violations of the Code of Ethics may subject an employee to sanctions from agencies or systems external to the University. Whether this occurs or not, the University retains the right to independently review and respond administratively to violations. The conduct of the review and response will be in accordance with contractual and regulatory guidelines.

IMPORTANT ETHICS REFERENCE MATERIALS

It is strongly recommended that every employee read and review the following ethics materials:

Connecticut General Statues Sections 1-79 through 1-89a, found at https://www.cga.ct.gov/current/pub/chap_010.htm
Ethics regulations Sections 1-81-14 through 1-81-38, found at https://www.jud.ct.gov/external/news/Reg-081.pdf
Guide to the Code of Ethics for Public Officials: http://www.ct.gov/ethics/lib/ethics/guides/public_officials_guide_10.pdf

The University’s Ethics Liaison is:

Kimberly Fearney, Associate Vice President and Chief Compliance Officer
Office of University Compliance
28 Professional Park Road (Unit 5084)
Storrs, CT 06268
Telephone Number: (860) 486-2530
Email: Kim.Fearney@uconn.edu

The contact information for the Office of State Ethics:

20 Trinity Street
Hartford, CT 06106
Office of State Ethics
Tel: (860) 263-2400
Fax: (860) 263-2402

POLICY HISTORY

Policy created: July 2006
Revisions: October 25, 2023; February 26, 2014; July 2009

FERPA Policy

Posted on May 24, 2011April 19, 2024 by Fearney, Kimberly

Title:	FERPA Policy
Policy Owner:	Office of University Compliance and Registrar
Applies to:	Faculty, Staff, Students, Others
Campus Applicability:	All Campuses
Effective Date:	August, 2016
For More Information, Contact	University Privacy Officer
Contact Information:	privacy@uconn.edu
Official Website:	http://ferpa.uconn.edu/

FERPA Policy

Policy Statement on Protection of Rights and Privacy of Students

A. Definitions: As used in this policy, the following terms have the following meanings.

1. 1. Alleged Perpetrator of a Crime of Violence: A student who is alleged to have committed acts that, if proven, would constitute any of the following offenses or attempts to commit the following offenses: arson; assault offenses; burglary; criminal homicide (manslaughter and murder); destruction, damage, or vandalism of property; kidnapping or abduction; robbery; and/or sexual assault.
  2. Attendance: Participation in University course(s) in person, or via paper correspondence, videoconference, satellite, Internet, or other electronic information and telecommunications technologies for students who are not physically present in the classroom. It also includes the period during which a person is working under a work-study program.
  3. Dates of Attendance: The period of time during which a student attends or attended the University. The term does not include specific daily records of attendance.
  4. Directory Information: Information contained in an Education Record of a student that by itself would not generally be considered harmful or an invasion of privacy if disclosed. Directory information includes: the student’s name; date of birth; addresses (including but not limited to physical address and email address); telephone number; PeopleSoft Number, NetID; school or college; major field of study; degree sought; student level (freshman, sophomore, etc.); degrees, honors, and awards received; residency/match information (for medical and dental students); dates of attendance; participation in officially recognized activities and sports, weight and height of athletic team members and other similar information including performance statistics, photographic likenesses and video of athletic team members; for student employees, employing department and dates of employment.
    The University reserves the right to amend this listing consistent with federal law and regulations and will notify students of any amendments by publication in the Annual FERPA Notification. Directory Information may only be disclosed in accordance with the provisions outlined in Section D. below.
  5. Disclosure Logs: Documents maintained by the appropriate University records custodians that records for each request for and each disclosure of Personally Identifiable Information of a student, and that indicates everyone who has requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it (other than those enumerated in section F. below).
  6. Education Records: Any records maintained in any form or medium by the University that are directly related to a student.
  7. FERPA: Family Educational Rights and Privacy Act, 20 U.S.C. sec. 1232g, et seq. as amended, and the regulations at 34 C.F.R. Part 99.
  8. Hearing Body:
    1. Storrs and Regional Campuses: One or more persons assigned by the Vice President of Student Affairs or designee to determine whether an educational record is inaccurate, misleading or otherwise in violation of the student’s privacy rights, and therefore should be amended or deleted from the student’s records.
    2. University of Connecticut Health Center (UCHC): One or more persons assigned by the Dean of Students for each school (Medical and Dental) or designee to determine whether an educational record is inaccurate, misleading or otherwise in violation of the student’s privacy rights, and therefore should be amended or deleted from the student’s records.
    Individuals who have a direct interest in the outcome of the hearing may not serve on the Hearing Body (i.e., may not be from the University department or division with whom the student has the conflict under FERPA).
  9. Legitimate Educational Interest: A University Official has a legitimate educational interest if it is in the educational interest of the student in question for the official to have the information, or if it is necessary for the official to obtain the information in order to carry out his or her official duties or to implement the policies of the University of Connecticut. Any University Official who needs information about a student in the course of performing instructional, supervisory, advisory, or administrative duties for the University has a legitimate educational interest.
  10. Parent: Includes a parent of a student, a guardian, or an individual acting as a parent in the absence of a parent or guardian.
  11. Personally Identifiable Information: A student’s name; the name of a student’s parent or other family member; the address of a student or student’s family; a personal identifier, such as the social security number or student number, or any portion thereof; biometric record (meaning, biological or behavioral characteristics used for automated recognition of an individual, such as fingerprints, retina and iris patterns, voiceprints, DNA sequence, facial characteristics, handwriting); other indirect identifiers, such as the student’s date of birth, place of birth, and mother’s maiden name; other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty; or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
  12. Student: One who is presently enrolled and attending or who has been enrolled and attended the University’s degree, non-degree and non-credit programs. It does not include deceased students.
  13. Student Code: Regulations governing student conduct; also known as “Responsibilities of Community Life: The Student Code.”
  14. University: for the purposes of this policy, “University” means the University of Connecticut, all campuses.
  15. University Official: The term “University Official” (sometimes called “School Official”) means any person employed by the University in an administrative, supervisory, academic, research or outreach, or support staff position (including law enforcement unit personnel and health staff). The term also includes any contractor, consultant, volunteer, or other party to whom the University has outsourced institutional services or functions where the outside party–
    1. Performs an institutional service or function for which University would otherwise use employees;
    2. Is under the direct control of the University with respect to the use and maintenance of education records; and
    3. Is subject to the requirements of FERPA governing the use and redisclosure of personally identifiable information from education records.
    Examples of “University Officials” include, but are not limited to: attorneys, auditors, collection agents, officials of the National Student Clearinghouse, or the; a person serving on the Board of Trustees; Reserve Officers’ Training Corps (ROTC) cadre members (limited to their relationship with students enrolled in the ROTC program and/or enrolled in ROTC courses); or a student serving on an official committee, such as a disciplinary or grievance committee, or assisting another University Official in performing his or her tasks.

B. Rights of Students

1. Students of the University have a right to:

1. 1. - Be provided a list of the types and location of educational records maintained by the University and the titles and contact information of the officials responsible for those records.
    - Inspect and review Education Records (except as excluded in section H. below), within 45 days of a written request being presented to the authorized custodian of the records in question;
    - Receive a response from the University to reasonable requests for explanations and interpretations of Education Records within ten (10) business days;
    - Request amendments to their Education Records if the student believes that they are inaccurate, misleading, or otherwise in violation of privacy rights. If the University refuses to make such amendments, the student shall have an opportunity for an administrative hearing to challenge the content of the record on the same grounds and to insert a written statement or explanation commenting upon the information in the record;
    - Inspect and review only such parts of educational material documents as relate to him/her or to be informed of such specific information;
    - Receive a copy, if desired, of all records supporting enrollment or transfer to another school, and have an opportunity for an administrative hearing to challenge the content of these records;
    - Revoke, in writing, any previously executed waiver of rights under FERPA, with respect to any actions occurring after revocation;

1. 1. - Inspect the Disclosure Logs maintained by appropriate University record custodians with regard to the student’s Education Record(s); and
    - File complaints with the Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue S. W., Washington, D.C. 20202-4605. Complaints may also be filed with the University’s Compliance Office by calling the Assistant Director of Compliance/Privacy at (860) 486-5256 or online at https://www.compliance-helpline.com/uconncares.jsp, or the UCHC Compliance Office by calling the Associate Education Compliance Officer at (860) 679-1280 or email compliance.officer@uchc.edu.

C. Disclosure of Education Records. Education Records or other Personally Identifiable Information (other than Directory Information, as described in Section D. below) may not be disclosed without the student’s prior written consent except in the following instances. For purposes of compliance with FERPA, the University considers all students, regardless of age or tax dependency status to be independent. Therefore, educational records will not be provided to parents without the written consent of the student, except where one or more of the exceptions below applies.

1. 1. To the student himself/herself, unless he/she has waived the right;
  2. To University Officials who have a legitimate educational interest in the records.
  3. To officials of other schools in which the student seeks or intends to enroll or has enrolled, as long as the disclosure is for purposes related to the student’s enrollment or transfer, and provided the student may upon request have a copy of the records so transferred;
  4. In connection with determining eligibility, amounts, and conditions, or enforcing terms of financial aid for which the student has applied or that which he or she has received;
  5. To comply with a judicial order or lawfully issued subpoena, provided the University makes a reasonable effort to notify the student of the order or subpoena in advance of the compliance therewith, unless such notification is not required by FERPA;
  6. To appropriate parties in connection with a health and safety emergency where the University determines that there is a articulable and significant threat to a student or any other individuals, where the knowledge of such information is necessary to protect the health or safety of the student or other individuals;
  7. To law enforcement agencies and to certain other governmental authorities and agencies as are enumerated in and required or permitted by FERPA;
  8. To a court in connection with legal action by the University against a student or a student’s parent or by a student or student’s parent against the University;
  9. To the parent of a student regarding the student’s violation of any Federal, State, or local law or of any rule or policy of the University, governing the use or possession of alcohol or a controlled substance where:
    1. The University has determined that the student has committed a disciplinary violation with respect to that use or possession; and
    2. The student is under the age of 21 at the time of the disclosure to the parent. Such disclosure will occur in accordance with the University’s Parental Notification Policy through the Division of Student Affairs. For more information, visit the Division of Student Affairs Community Standards website at: http://www.community.uconn.edu.
  10. To a victim of an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense. Such disclosure may only include the final results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may disclose the final results of the disciplinary proceeding regardless of whether the University concluded a violation was committed;
  11. Disclosure of the final result of a disciplinary proceeding where the alleged perpetrator-student is found to have violated University policy with respect to a criminal allegation. Such disclosure may be made (even to members of the public in certain circumstances) where the University has determined through its disciplinary proceedings that a student is (a) an Alleged Perpetrator of a Crime of Violence or a Non-forcible Sex Offense; and (b) with respect to the allegation made against the student, the student has committed a violation of the Student Code. Such a disclosure may only include the Final Results of the disciplinary proceedings conducted by the University with respect to the alleged crime or offense. The University may not disclose the name of any other student, including a victim or witness, without the prior written consent of the other student. This paragraph applies only to disciplinary proceedings in which the Final Results were reached on or after October 7, 1998;
  12. To authorized representatives of the federal, state and/or local government as permitted by FERPA in connection with an audit of federal- or state-supported education programs or with the enforcement of or compliance with federal legal requirements relating to those programs.
  13. To accrediting organizations to carry out their accrediting functions; and
  14. To organizations conducting studies for, or on behalf of, educational agencies or institutions to:
    1. Develop, validate, or administer predictive tests;
    2. Administer student aid programs; or
    3. Improve instruction.
    Disclosures made pursuant to this paragraph are subject to the requirements that (i) the studies are conducted in a manner that does not permit personal identification of parents and students to individuals other than representatives of the organization; and (ii) the information is destroyed when no longer needed for the purposes for which the study was conducted.
  15. Pursuant to a student record release request made under the Solomon Amendment. (See section E. below.)

D. Disclosure of Directory Information/Limited Directory Information Policy:

The University hereby gives notice that the categories of information defined herein as Directory Information may be released without the prior written consent of the student under the circumstances enumerated below. The University reserves its right to determine when and to whom it is appropriate to release Directory Information in response to third party requests. Any release of information deemed to be appropriate by the University will only occur as enumerated below:

1. The following categories of Directory Information may be disclosed to anyone who so requests:

Name
NetID
PeopleSoft Number
School or College
Major Field of Study
Degree Sought
Student Level
Degrees, Honors & Awards Received
Residency/Match Information (medical/dental students)
Dates of Attendance
Participation in Officially Recognized Activities and Sports
Weight and Height of Athletic Team Members and Other Similar Information Including Performance Statistics
Photographic Likenesses and Video of Athletic Team Members
For Student Employees, Employing Department & Dates of Employment

2. In addition to the information in category #1, the following categories of Directory Information may be disclosed to the UConn Foundation (including the UConn Alumni Association) and/or the UConn Law School Foundation:

Date of Birth
Addresses (physical and email)
Telephone Number

3. In addition, any member of the University community with a NetID may access student email addresses, as long as the access is for University-related purposes. However, such individuals may not use any student emails accessed through this process for commercial purposes or otherwise in violation of other University policies or applicable state or federal law.

4. Opting Out of Directory Information: Students who wish to opt-out of having their directory information disclosed without their prior consent must make the request in writing. At the Storrs and Regional Campuses, all requests shall be directed to the Office of the Registrar, Wilbur Cross Building, Unit 4077, Storrs, CT 06269-4077. At UCHC, all requests shall be directed to the Student Services Center, 263 Farmington Avenue, Farmington, CT 06030-1827. Such requests shall apply only to subsequent actions by the University and shall remain in place until removed by written request of the student. A student may not use the right to opt out of Directory Information disclosures to prevent the University from disclosing or requiring a student to disclose the student’s name, identifier, or institutional e-mail address in a class in which the student is enrolled. Student employees must contact the Student Employment division within the Office of Student Financial Aid Services to restrict access to any employment-related Directory Information. The University will not use Social Security Numbers as a means of verifying the identity of a student, nor to confirm identity of the student upon the request for the release of Directory Information about the student.

E. Military Access to Education Records. The Solomon Amendment is not a part of FERPA, but it allows military organizations access to information for the purposes of military recruiting which information may otherwise be protected from disclosure under FERPA. Failure to comply with this requirement could result in the loss of various forms of federal funding including various forms of Federal Student Aid.

At the University of Connecticut, all items included under the Solomon Amendment’s list of required information are included within the University’s definition of “Directory Information.” These include name, addresses, telephone numbers, age, major, dates of attendance and degrees awarded.
Information released is limited to military recruiting purposes only. The request for information must be in writing on letterhead that clearly identifies the military recruiting organization. Military recruiters must be from one of the following United States military organizations: Air Force; Air Force Reserve; Air Force National Guard; Army; Army Reserve; Army National Guard; Coast Guard; Coast Guard Reserve; Navy; Navy Reserve; Marine Corps; Marine Corps Reserve.
If a student requests that their Directory Information be withheld under section D.4. of this policy, the student’s records will not be released to military recruiters.

F. Disclosure Logs. The appropriate University records custodian shall maintain a log of each request for and each disclosure of Personally Identifiable Information from the Education Records of a student, that indicates the persons who have requested or obtained Personally Identifiable Information and their legitimate interests in obtaining it. However, this requirement does not apply to:

Disclosures pursuant to the written consent of the student, when the consent is specific with respect to the party or parties to whom the disclosure is to be made;
Disclosures to University Officials, when it has been determined that the official has a legitimate educational interest; and
Disclosures of Directory Information; and
Disclosures to the student upon the student’s own request.

G. Redisclosure. University Officials who disclose personally identifiable information from an Education Record must inform the recipient of the information that he/she/it may not redisclose that information without the consent of the student, and that the recipient may only use the information received for the purpose for which the disclosure was made, except where one of the exceptions in Section C. above applies.

H. Records Excluded from the Definition of Education Records. The following materials, information, and records which are excluded from the definition of Education Records are not available to students for inspection, review, challenge, correction, or deletion:

Confidential letters and statements of recommendation which were placed in the Education Records prior to January 1, 1975, if they are not used for purposes other than those for which they were specifically intended;
Confidential letters and statements of recommendations, used solely for the purposes for which they were specifically intended, if the student has waived the right to inspect and review recommendations:
1. regarding admission to an educational institution,
2. regarding an application for employment, and
3. regarding the receipt of an honor or honorary recognition;
Financial records and statements of the student’s parents or any information contained therein;
Records of instructional, supervisory, or administrative personnel or educational personnel ancillary thereto, which are kept in the sole possession of the maker thereof, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record;
Records which are created or maintained by a physician, psychiatrist, psychologist or other recognized professional or paraprofessional acting or assisting in that capacity, used only in providing treatment to the student, and not available to anyone other than persons providing such treatment, except that such records may be personally reviewed by a physician or other appropriate professional of the student’s choice;
Records made and maintained in the normal course of business which relate exclusively to the individual in his or her capacity as an employee and are not available for any other purpose; this exclusion does not apply to an individual who is employed by the University as a result of his/her status as a student (i.e., interns, graduate assistants, work-study, etc.);
Records that only contain information about or related to a former student once he or she is no longer enrolled at the University (e.g., information regarding alumni or regarding individuals who attended the University at some point but are no longer enrolled);
Records of a law enforcement unit of the University created and maintained by that law enforcement unit for the purpose of law enforcement. This exception does not include those records created by a law enforcement unit, even if the records were created for law enforcement purposes, if such records are maintained by a component of the University other than the law enforcement unit; and
Grades on peer-graded papers before they are collected and recorded by a teacher.

Student Rights to Inspect and Challenge Education Records. The University shall provide a student the opportunity to challenge the content of his or her Education Records where the student believes the record(s) to be inaccurate, misleading, or otherwise in violation of privacy rights, and to correct, delete, or insert written statements of explanation into such record(s). This does not give a student a right to contest or challenge an assigned grade. Although disagreements may be settled through informal meetings and discussions, either the student or the University may request an administrative hearing to resolve the dispute. The student or University administrator seeking the hearing shall make his or her request in writing.

Send a written request to:

University Privacy Officer
University of Connecticut
Office of University Compliance
28 Professional Park Unit 5084
Storrs, Connecticut 06268-5084

The Hearing Process:

The hearing shall be conducted and decided within a reasonable period of time following the request, and the student shall be given notice of the date, time, and place reasonably in advance of the hearing. Normally, the hearing will be conducted within ten (10) business days following the date the hearing request has been received.
The student will have, at the formal hearing, the opportunity to present evidence and argument to a Hearing Body in support of his or her contention that the records are inaccurate, misleading or otherwise inappropriate. The student may, at his or her own expense, be assisted by one or more individuals of his or her own choice, including an attorney. The student may present evidence and question witnesses. The burden shall lie with the student to show that it is more likely than not (preponderance of the evidence) that the University department should have made the student’s requested changes to his or her records, and/or that a violation of the student’s rights under FERPA has occurred.
The University department with whom the student has the conflict may present a case in rebuttal with the same aforementioned procedural rights. The University department shall be provided an opportunity to present evidence relevant to the issues raised by the student;
The hearing shall be conducted by a Hearing Body who will hear all testimony, review all evidence presented at the hearing and render a decision. The Hearing Body shall be appointed by the Vice President of Student Affairs for the Storrs and Regional Campuses, or by the Dean of Students for each school (Medical and Dental) at UCHC, provided that person(s) does not have a direct interest in the outcome;
The Hearing Body shall ensure that the decision is rendered to the student in writing within a reasonable time after the conclusion of the hearing, is based solely upon the evidence presented at the hearing, and shall include a summary of the evidence and the reasons for the decision. The decision of the Hearing Body shall be final.
If the matter is not resolved to the satisfaction of the student, the student may draft a written response to be included with the Education Record(s) in question that details the student’s issue(s) with the Education Record(s) in question, and a description of why the student believes the Education Record(s) in question to be inaccurate, misleading, or otherwise in violation of privacy rights.

Employment and Contracting for Service of Relatives, Policy on

Posted on May 24, 2011February 6, 2024 by Fearney, Kimberly

Title:	Employment and Contracting for Service of Relatives, Policy on
Policy Owner:	Office of University Compliance and the Office of Faculty & Staff Labor Relations/Human Resources
Applies to:	Faculty, Staff, Others
Campus Applicability:	All Campuses
Effective Date:	February 7, 2011
For More Information, Contact	Office of University Compliance and the Office of Faculty and Staff Labor Relations (Storrs) or Human Resources (UConn Health)
Contact Information:	UConn Health: (860) 679-4180 or (860) 679-2426 Storrs/Storrs Based Campuses: (860) 486-2530 or (860) 486-5684
Official Website:	https://compliance.uconn.edu/ethics-overview/ or http://lr.uconn.edu

PURPOSE

The employment or contracting for service of relatives in the same department or area of an organization may cause conflicts and serve as the basis for complaints concerning disparate treatment and favoritism as well as violations of the state’s Ethics statute.

This policy is established to protect against such conflicts and complaints, and to provide for the ethical and legally consistent treatment of individuals with relatives seeking employment or who are employed by the University.

POLICY

No employee of the University of Connecticut may be the direct supervisor of or take any action which would affect the financial interests of one’s relative. This may include decisions regarding appointment, award of a contract, promotion, demotion, disciplinary action, discharge, assignment, transfer, approval of time-off, and approval of training or development opportunities, as well as conducting performance evaluations or participating in any other employment action, including serving on a search committee acting on a relative’s application, or otherwise acting on behalf of a relative except as noted under “Procedure” below. Further, no employee may use his/her position to influence an employment action of a non-relative if such action would benefit one’s relative.

For purposes of this policy, relative is defined as: 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.

PROCEDURE

The University recognizes the potential for conflict of interest, claims of disparate treatment and/ or discrimination in the employment of relatives in the same department, work unit or in a direct or indirect supervisory relationship. The University further recognizes that there are infrequent but compelling circumstances under which such employment relationships may be in the best interests of the institution. Thus, to protect both the involved employee and the institution in those situations, the following procedure must be followed.

No employee may sign any document that would affect an employment action on behalf of a relative.
An employee who is confronted with an employment decision or action involving a relative must inform the immediate supervisor in advance, in writing, of the situation. The employee will describe the relationship and the proposed action requiring a decision by using Section 1 of the Conflict of Interest (COI) Disclosure form available here.
The COI is submitted through the supervisory chain to the dean/director and then to the appropriate senior manager. Using Section 2 of the COI Disclosure form, the dean/director shall propose to the senior manager an appropriate conflict resolution plan (CRP) to resolve the conflict. In general the CRP should address how the required decisions will be made to avoid any conflicts.
The senior manager shall determine if the proposed plan for the resolution of the conflict is within the best interest of the institution, and approve or modify the plan using Section 3 of the COI Disclosure form. The written resolution and implementation of the plan shall be communicated to the dean/director and through the supervisory chain to the employee(s) involved in the conflict of interest.
The supervisor, dean/director, or provost/vice president (the first level outside of the reporting process of each person in the conflict) shall oversee the implementation of CRP.
Should the conflict involve the provost or a vice president, then the actions/decision shall be directed to the president or designee.

Note: Under no circumstances will the University approve the employment of dependent children or step-children as student employees under direct or indirect supervisory relationships.

* Senior Manager is defined as the Provost or Vice President level.

POLICY HISTORY

This policy was approved by the Board of Trustees on 11-09-2010.

Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on

Posted on May 17, 2011May 13, 2024 by Fearney, Kimberly

Title:	Consulting for Faculty and Members of the Faculty Bargaining Unit, Policy on
Policy Owner:	Office of the Provost
Applies to:	Faculty and members of the faculty bargaining units; Management-exempt personnel with faculty appointments
Campus Applicability:	All Campuses
Effective Date:	June 29, 2022
For More Information, Contact:	Faculty Consulting Office
Contact Information:	Storrs and Regional Campuses: Sarah Croucher, sarah.croucher@uconn.edu UConn Health: Carla Rash, rash@uchc.edu
Official Website:	http://consulting.uconn.edu/

1. BACKGROUND

The University recognizes the benefits derived from faculty members participating in consulting activities with outside entities. Such activities are vital for professional service, provide intellectual enrichment of faculty members and students, may foster economic development, and enhance the reputation of the University. Participation in such activities is a norm for faculty at all highly ranked U.S. public research universities. All activities where outside compensation is received that are related to the expertise of a faculty member fall within the purview of this policy, as are any activities with faculty affiliated companies.

2. PURPOSE

This policy provides a framework for consulting work with external entities to ensure compliance with the State of Connecticut Code of Ethics (Conn. General Stat §1-84(r)), other applicable policies, and to ensure such work does not conflict with University employment.

3. SCOPE

This policy applies to all faculty at the University of Connecticut and the University of Connecticut Health Center, and all staff eligible to be members of the faculty bargaining units (hereafter described as “faculty members”). The policy applies to management-exempt employees only when they have a base faculty appointment, as determined by their appointment letter. Faculty members who are employed by the University below 0.5 FTE (full-time equivalent) do not need approval to engage in consulting activities. However, such faculty may voluntarily elect to request prior approval for consulting activities. Once a faculty member in this position has requested approval to consult, all subsequent consulting activities in that reporting year must also obtain such approval.

4. DEFINITIONS

Consulting: an activity (e.g., provide services, give advice or analysis) undertaken by a faculty member for compensation as a result of their expertise or prominence in their field, while not acting in their official capacity as a State employee (i.e., in their own time). Activities such as serving on grant review panels, giving talks, or reviewing academic works are classified as consulting when undertaken for compensation. Paid or unpaid work conducted for a faculty affiliated company is also considered consulting.
Compensation: any form of payment received for the consulting activity. Compensation for consulting activities includes, but is not limited to; honoraria, stipends, payments in goods or services, stocks or stock options, other interests of value, or any forms of compensation (including “luxury travel”) above necessary expenses, even if this is intended to support costs associated with undertaking the activity.
Contracting entity: the business, nonprofit organization, government body, individual, or other organization that engages and compensates the faculty member for the consulting activity.
Faculty affiliated company (FAC): A faculty affiliated company (or other legal entity) is a for-profit or not-for-profit business where a faculty member or member of their immediate family: 1) is a director, officer, owner, or limited or general partner or, 2) is a beneficiary of a trust, or holder of stock constituting five percent or more of the total outstanding stock of any class.
Time due to the University: any time necessary for successfully carrying out the workload duties assigned to a faculty member. The University’s Bylaws and policies prohibit faculty from consulting on “time due to the university.”
Normal work time: the usual time during which a faculty member is expected to perform their job duties. These times and job duties may be defined in specific appointment letters, workload policies, or other workload assignment documentation.
Reconciliation: the process of closing out each approved consulting request after the activity has taken place (or was due to take place if it does not occur) by confirming or updating information regarding the time spent consulting and the compensation received.

5. POLICY

All full-time faculty members must receive written permission from the appropriate supervisory hierarchy prior to engaging in any consulting activity. All consulting requests and reconciliations must be submitted via the University online consulting request system. Faculty must adhere to the University’s procedures associated with this policy.

Consulting approval is not required for compensation received from royalties.

The provost will submit an annual report of consulting activities for all faculty members to the Joint Audit and Compliance Committee of the Board of Trustees. The University's Office of Audit and Management Advisory Services (AMAS) shall develop and implement a plan of regularly recurring monitoring and audits to ensure the complete and accurate implementation of this policy.

The disclosure of proprietary information (i.e., intellectual property owned in part or in total by the University) is prohibited when consulting unless specific permission is granted.)

6. ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Bylaws, General Rules of Conduct for all University Employees, and applicable collective bargaining agreements.

Faculty members who do not receive prior approval under this policy are subject to the jurisdiction of the Office of State Ethics. In addition, the faculty member may be subject to sanctions issued by the University for violating this policy, as outlined in the associated Procedures.

7. PROCEDURES

Procedures on Consulting for Faculty and Members of the Faculty Bargaining Unit are linked here.

POLICY HISTORY

*Policy Created: September 25, 2007

*Revisions: 06/29/2022, 06/29/2019, 03/25/2015, 04/24/2013, 11/12/2012, 04/13/2011, 04/20/2010

*Approved by the Board of Trustees.

Compliance Training Policy

Posted on May 17, 2011June 27, 2024 by Fearney, Kimberly

Title:	Compliance Training Policy
Policy Owner:	Office of University Compliance
Applies to:	Workforce members
Campus Applicability:	All University campuses, including UConn Health
Effective Date:	June 27, 2024
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530
Official Website:	https://compliance.uconn.edu/

PURPOSE

Training is an essential part of an effective compliance and ethics program. As recipients of federal funding, the University is required to provide all Workforce Members, including graduate assistants and affiliated parties, with training on the elements of the University’s Compliance Program and the University’s expectations that all will act in accordance with all applicable University policies, and federal and state laws and regulations. Compliance training is intended to benefit the University community by helping to ensure that its members understand their responsibilities and by fostering a culture of compliance and ethical behavior.

DEFINITIONS

Workforce Members: Employees, volunteers, trainees, and other persons whose conduct, in the performance of work for the University, is under the direct control of the University, whether or not they are paid by the University.

POLICY STATEMENT

Training Requirements

All University Workforce Members are required to complete compliance training. Specific training requirements may differ in content, delivery, or frequency based on a Workforce Member’s role and responsibilities at the University in conjunction with other University policies, laws, and regulations.

Additional or Specialized Training

Workforce Members may be required to participate in additional and/or specialized compliance-related training to maintain the University’s compliance with applicable University policies, and federal and state laws and regulations. Training may be provided by the Office of University Compliance or another University department or entity with compliance-related responsibilities.

Attestation

Upon completion of any required compliance training, Workforce Members may be required to attest that they completed the training, understand the content and resources provided, as well as the potential disciplinary actions or sanctions that may result from any incidents of non-compliance with University policies and applicable laws and regulations.

ENFORCEMENT

Failure to complete assigned compliance trainings by the established deadline may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and/or the University of Connecticut Student Code. Management, in consultation with the Department of Human Resources and in accordance with collective bargaining agreements, will be responsible for issuing appropriate disciplinary action for non-compliance.

POLICY HISTORY

Policy created: 08/13/2008 Approved by Executive Compliance Committee

Revisions: 06/27/2024 Approved by the Senior Policy Council and the President; 06/11/2020 Approved by University Compliance Committee and UConn Health’s Administrative Policy Committee on 06/25/2020.

Code of Conduct

Posted on May 17, 2011September 26, 2023 by Fearney, Kimberly

Title:	Code of Conduct
Policy Owner:	Office of the President
Applies to:	Faculty and Staff
Campus Applicability:	All Campuses
Effective Date:	February 22, 2011
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530
Official Website:	https://compliance.uconn.edu/

This document serves to guide the daily operations of our University system including:

The Storrs campus;
Schools of Law and Social Work;
Regional campuses throughout the State;
UConn Health

Letter from the President

Ethics Statement

Introduction

Campus-Wide Standards

Education Standards

Research Principles and Standards

Public Engagement and Outreach Standards

Patient Care Standards

Business, Fiscal and Legal Standards

External Relations and University Advancement

Resources, Additional Information, and Reporting

Letter from the President

Dear Colleagues:

The University of Connecticut is committed to assuring the highest standard of integrity in all aspects of University life and in all University and University-sponsored activities. While this goal is simply stated, its attainment requires concerted effort on the part of all members of the University community, particularly faculty, administrators and staff. Federal, state and local regulations which govern our activities are increasingly complex, and as the University’s activities expand in size, scope and prominence, it is important that all of us understand relevant policies and know what is required in terms of compliance and reporting.

The University of Connecticut Board of Trustees is the body that is ultimately responsible for ensuring full compliance. At the Board’s direction, the University has established a Compliance Program to help in our efforts to adhere to all federal, state and local regulatory requirements. A key ingredient of an effective Compliance Program is the establishment of a Code of Conduct. This Code of Conduct was developed with input from faculty, administrators and staff.

This Code serves to guide the conduct of University activities in support of the University’s mission and is designed to serve three key purposes:

To set the basic standards of workplace behavior that the University expects of all faculty, administrators and staff.
To state publicly the University’s long-term commitment to the highest standards of integrity in education, research, health care, public engagement and service.
To assure that faculty, administrators and staff understand their shared responsibility for keeping the University in full compliance with all applicable laws, regulations and policies.

Please read the Code carefully, and take all steps necessary to apply its standards. The Office of University compliance is responsible for monitoring compliance and serving as a resource for questions and guidance on the Code, and on the University policies and procedures that spell out compliance requirements in greater detail.

A key element in assuring University-wide compliance is a system for reporting potential violations. In an institution this large and active, there may be areas of confusion; regrettably, there may also be instances in which individual behavior does not meet appropriate ethical expectations. Any University employee who observes a possible violation of law, regulation, policy or approved procedure has an obligation to report it. While a key element is reporting inappropriate activity, I want to emphasize that the most important element of any compliance or ethics program is working cooperatively to assure a positive climate of openness and integrity. Great universities function as true communities in which faculty, administrators, staff and students collaborate to achieve common goals. That holds true for instruction, research, public engagement, service and, at the most fundamental level, ethical compliance.

I want to thank you for understanding and adhering to these standards, and for your commitment to the highest level of ethical conduct in fulfillment of our institutional responsibilities.

Sincerely,

Radenka Maric

The University of Connecticut Ethics Statement

The standards contained in this Code of Conduct reflect the University of Connecticut’s core values, as they have been articulated over time by generations of faculty, staff, administrators, students and the State of Connecticut. These values are essential and enduring tenets of our organization. A statement of these values, while reiterating concepts already well understood, is helpful in outlining the context in which our Code will operate. Please be advised that violation of the standards in this Code of Conduct may result in appropriate disciplinary measures up to and including dismissal.

Knowledge: Members of the University community value truth, the pursuit of truth, intellectual curiosity and academic freedom. Our faculty and students seek to create new knowledge and are committed to sharing ideas, research findings and the products of intellectual and creative pursuits with the broader community

Honesty: Members of the University community are truthful and sincere in their words and actions and do not intentionally mislead others or provide inaccurate information.

Integrity: Institutional and individual behaviors at the University reflect fundamental moral and ethical values. Our actions are beyond reproach and avoid both the fact and the appearance of impropriety.

Respect: The University honors and respects individuality and demonstrates tolerance for the personal beliefs and cultural differences of all individuals. As members of an academic community, we seek to foster a spirit of civility and collegiality through open and honest communication. We strive to protect the health, safety and well-being of all persons. We protect the private and confidential information that is provided by our patients and research participants, faculty, administrators, staff, students, volunteers and others. We value an environment that is free from harassment, intimidation, bullying, incivility, disrespect and violence.

Professionalism: The University and its members expect that the professional standards and requirements that are applicable to the academic, research, clinical, engagement, administrative and other professions comprising our community will be followed. We are responsible and accountable for our actions and are expected to make reasonable efforts to comply with all applicable federal, state and local government laws and regulations. As individuals and as an institution, we also strive to follow ethical business practices and to act as good stewards of the resources made available to us.

Introduction to the University of Connecticut Code of Conduct

In all its endeavors, the University of Connecticut is dedicated to excellence that is demonstrated through national and international recognition. As Connecticut’s public research, land-grant and sea-grant university, through freedom of academic inquiry and expression, we create and disseminate knowledge by means of scholarly and creative achievements, graduate and professional education, and public engagement and service. Through our focus on teaching and learning, the University helps every student grow intellectually and become a contributing member of the state, national and world communities. Through teaching, research, engagement and service we embrace diversity and cultivate leadership, integrity and engage citizenship in our students, faculty, staff and alumni. As our state’s flagship public land and sea grant institution, we promote the health and well being of Connecticut’s citizens through enhancing the social, economic, cultural and natural environments of the state and beyond.

If you are faced with an ethical issue, you should consult this Code of Conduct as well as current University policies and procedures. You are responsible and accountable for addressing your ethical dilemmas. Consultation with your supervisor, other appropriate colleagues, or the Office of University Compliance is appropriate and valued.

The Code of Conduct includes “Questions to Ask Yourself” after each set of Standards. These questions are intended to be thought provoking and assist employees by providing examples of matters that each of us may face during our employment with the University. For guidance regarding individual situations that relate to any of these or other questions, please feel free to contact the Office of University Compliance.

Campus-Wide Standards

The University of Connecticut values all members of its community and recognizes that each person contributes to the overall success of the institution. The University further recognizes that it is through the efforts of its faculty, administrators and staff that it achieves national and international prominence and delivers a world class education to its students. The culture of the University is one of respect, civility, trust, cooperation and collaboration among all its members. We believe all members of the University community are entitled to an environment that ensures collegiality and mutual respect.

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. The University supports the efforts of its faculty, administrators and staff to achieve and maintain professional standards.
The University provides equal opportunity and access to its employment, programs, benefits and services.
Supervisors have a particular responsibility to support the Code of Conduct and to demonstrate compliance within their units.
Relationships of an inappropriate personal nature between supervisors and those they supervise are prohibited.

Civility

The University values an environment that promotes a spirit of civility and collegiality, while fostering open and constructive intellectual debate.
All members of the University community have a responsibility to treat each other with consideration and respect. Managers and supervisors have an elevated responsibility to demonstrate these behaviors and support their expression in the workplace.
Engaging in behaviors that harass, intimidate, bully, threaten or harm another member of the University community does not support a respectful and civil work environment.

Non-Discrimination

The University encourages and respects diversity within the university community and does not allow discrimination on the basis of age, race, national origin, religion, disability, sex, sexual orientation or any other characteristic protected by law in any activity or operation of the institution.

Harassment

The University affirms its dedication to foster a community that condemns all forms of discrimination or acts of intolerance including sexual harassment, intimidation and retaliation.

Confidentiality

Confidentiality of faculty, staff, patient and student records is respected and maintained in accordance with University policies and procedures, federal laws and state regulations. We use such records for legitimate purposes only and in accordance with proper authorization.

Computer/Telecommunications Use

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. Those who use the computer and telecommunication networks are responsible for the appropriate use of these resources. We understand, support and abide by the policies concerning the ethical and responsible use of computers and electronic information at the University of Connecticut.

Regulatory Compliance

The University of Connecticut Office of University Compliance strives to ensure that we meet the highest possible standards where relevant federal, state and local regulations, laws and guidelines are concerned. This office supports ethical conduct by all faculty, administrators and staff and requires ongoing monitoring of policies, procedures and practices. Education is a key component of this program.

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.

Conflict of Interest

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.
We will not engage in outside activities which will create an actual conflict of interest and will strive to avoid the appearance of a conflict. If faced with a potential conflict of interest, members of the university community shall disclose the nature of the conflict to the appropriate parties.
We do not accept gifts, including food and beverage, from vendors, lobbyists or any other person or entity that is doing business with or seeking to do business with the University unless permitted under the Connecticut Code of Ethics for Public Officials.
We do not accept secondary employment that will impair our independence of judgment as to our official duties or which will require us to disclose confidential information.
We will not use our state positions for personal financial gain beyond our official compensation, or for the financial benefit of our family members or domestic partners.
We will not use state resources for personal use or for use unrelated to our University responsibilities.

Questions to Ask Yourself

Have I treated others as they wish to be treated?

Do I make discriminatory and harassing statements?

Have I used my position to intimidate or isolate others?

As a faculty member or staff member, should I accept a gift from a student?

Do I frequently use my university telephone for personal phone calls?

Do I use my contacts at the University to help my outside business?

Do my outside professional activities create an appearance of a conflict of interest?

Do I maintain appropriate professional relationships with students, colleagues, patients, clients and customers?

Have I used my position to gain employment for a family member?

Even if I have access to certain records, do I have the authority to view them and/or distribute them to others?

Do I know what to do if I think that a University record have been accessed inappropriately by someone inside or outside the University?

Do I take shortcuts that create a safety hazard?

Education Standards

The University of Connecticut recognizes education as one of its primary missions and strives to maintain a professional environment conducive to the development of its students. To that end, the University believes that the purposes of an educational institution are best served by attracting and developing scholars of proven professional and personal competence and integrity and by assuring those teachers and scholars freedom to expand human knowledge and understanding.

We educate students from a wide range of backgrounds and respect differences in each individual’s heritage and goals.
We respect the individual choices that students make for career paths.
We respect each student as a valuable individual regardless of age, race, color, nationality, ethnicity, ancestry, marital status, gender, disability, religion, sexual orientation or personal beliefs.
We acknowledge and support students’ rights to question faculty members, the administration and staff in good faith.
We comply with all applicable statutes and regulations.

Student conduct is governed by the applicable codes of conduct and professional standards of conduct adopted by their schools. While this Code applies primarily to faculty, administrators and staff, its underlying principles are, however, common to codes and regulations governing students.

Athletics

The Division of Athletics operates a broad-based program of intercollegiate athletics and recreational and intramural opportunities that reflect the ethical philosophy of the University, the interest of the student body and the desires of the University’s internal and external constituencies.

We offer student-athletes the opportunity to excel in academic achievement and athletic accomplishments.
We foster among our students a sense of citizenship, leadership and social responsibility and encourage adherence to the highest standards of integrity and ethics.
We promote principles of good sportsmanship, honesty and fiscal responsibility in compliance with University, state, National Collegiate Athletic Association (NCAA) and conference regulations.
We promote and support the University’s comprehensive commitment to diversity and equity, providing equitable opportunity for all students and staff, including women and members of minority groups.

Questions to Ask Yourself

Do I foster an environment that is conducive to learning?

Am I providing each student an equal opportunity to learn?

Do I react negatively when students challenge or critique my interpretation of source material?

Do I protect the privacy of each student’s academic record and personal information?

Are my grading practices fair and understood by all of my students?

Do I regularly update my teaching materials?

Am I a role model for my students regarding professional values?

Do I acknowledge and support providing student athletes equitable and appropriate opportunities to excel in academic achievement?

Research Principles and Standards

The University of Connecticut is committed to the highest standards of professional conduct and integrity in research. These standards include honesty, trustworthiness, objectivity, accountability, openness, respect and fairness when dealing with other people, a sense of responsibility towards others and loyalty to the ethical principles espoused by our institution.

The University expects these standards to be maintained by all academic, research and relevant support staff, students and their supervisors and other individuals conducting research or involved in the peer review process within or on behalf of the University. Prompt reporting to the appropriate institutional administrative committees of violations of human subjects’ protection, laboratory safety, or humane treatment of animals is expected.

We understand that academic freedom is essential to creating an atmosphere in which scholarship flourishes. Promotion of intellectual freedom is consistent with assuring a climate of integrity and the University has the right and the obligation to inquire into all instances of alleged or apparent misconduct in scholarly activities.

Scholarly Integrity

We properly collect, record and maintain research data.
We take responsibility for all publications and presentations of which we are author or co-author.
We appropriately acknowledge, in publications and presentations, those who have contributed to our research.
We grant access to our research data to co-investigators involved in generating the data.
We grant reasonable access to our research equipment and resources to other University investigators involved in research.
We, the University and its faculty, administrators and staff, do not interfere with the research conducted by students or faculty.
We do not tolerate plagiarism, falsification, or fabrication of research data, or other scientific misconduct.

Human Research

We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, when performing studies involving human subjects.
We respect human research participants and are committed to their safety.
We protect human subjects by securing institutional review and approval for any research.
We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
We engage all human subjects, or their appropriate representatives, before initiating a research protocol, in a meaningful informed consent process including explanations of possible risks and benefits.
We allow potential or current participants to withdraw from a study at any time without prejudice.
We notify human subjects in a timely fashion of any serious adverse events associated with a human subjects study.
We conduct appropriate education and training before initiating a human subjects study.

Animal Research

We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, regarding the care, transport, maintenance and use of animals.
We are committed to the humane treatment of animals in research.
We protect research animals by securing appropriate institutional review and approval for any research.
We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
We conduct appropriate education and training before initiating animal research.

Laboratory Safety

We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, concerning laboratory safety.
We seek prior approval of appropriate University committees when research involves hazardous chemical substances, bio-hazardous materials or radioactive materials.

We properly document, store, handle, transport and dispose of radioactive, bio-hazardous and hazardous chemical materials, pharmaceuticals and investigative drugs.
We participate in appropriate education and training before initiating studies involving such materials.
We comply with all workplace safety and health regulations and will report unsafe conditions, equipment or practices to our supervisors or other appropriate University officials.
We attend required instructional and training sessions when dictated by funding or oversight agencies.

Research Support

We use research funds only for their designated purposes.
We accurately account for time and effort related to research funding.
We disclose financial conflicts of interest to University administrators and, as appropriate, manage such conflicts in accordance with existing policies and procedures.
We properly acknowledge sponsorship of research in our publications and presentations.

We disclose inventions produced from our research to the University so that consideration is given to the protection of intellectual property.

Questions to Ask Yourself

Do I work safely in the lab?

Have I received training and approval to use research materials?

Have I collected data and documented my research accurately?

Did I face a conflict of interest today? Does it bias my research?

Do I protect the safety and well-being of my human or animal subjects?

Did I obtain proper consent from my human subjects?

Do I respect the privacy of research participants? Do I appropriately protect the confidentiality of their research data?

Public Engagement and Outreach Standards

The primary purpose of public engagement is to serve external constituents in a manner that leads to enhanced teaching and research. Public engagement efforts impact on the reputation of the University. Engaged scholarship, as a component of public engagement, results from public engagement and outreach. It focuses on those activities that promote advanced understanding and creative works in a mutually beneficial manner. Public engagement, which includes outreach and public service, consists of all activities where the University offers its resources, both human and physical, to external constituencies in such a manner where there is a partnership or that engaged scholarship results. These efforts are on behalf of the public good and not for private gain. The term University resource refers to those activities and entities that the University makes available to its various constituencies which may involve a cost to access.

As a land and sea grant university, the University of Connecticut is committed to our mission that includes public engagement as measured by the impact of teaching and research on the world outside of the insitution. In the spirit of true partnership, we seek to expand our interactions with groups beyond our campuses in areas of mutual concern and enhance their access to the resources available at the University. In addition to collaborations in the arts and humanities, we encourage constructive partnerships in new areas of interdisciplinary excellence, such as Health and Human Behavior, the Environment, and Human Rights. Through broadened access and reciprocal interaction, we realize synergistic outcomes that further strengthen the University and benefit the people of Connecticut as well as those beyond the state borders.

We believe the reputation of the University is tied to its responsiveness to the needs of the citizens and communities of the State.
We reach out to and engage communities in reciprocal partnerships.
We are respectful of our community members, demonstrate cultural competence in their interactions, and comply with University policies while engaged in and with communities, just as we would on campus.
We strive for responsible engaged scholarship and community-based programs to the benefit of communities by involving our partners in the planning, execution, and dissemination of the knowledge gained by such programs.
We translate and disseminate research results to real world applications to address problems.
We recognize and respect the knowledge and behaviors of our partners as we work in a collaborative environment.
We effectively communicate these standards and values with the organization.
We actively engage students in community experiences as part of our service learning priority.

Practical Considerations for Public Engagement and Outreach Principles and Standards

Have I ensured that the public engagement effort is consistent with the University’s mission and vision?

How do I solicit input regarding community needs when designing, planning, and conducting my engaged scholarship or community-based project?

How can I work with community members as equal and collaborative partners in all phases of the project, from planning to dissemination of findings, and avoid the perception of using the group for my gain?

How do I handle the findings of my work to ensure confidentiality when appropriate?

Am I culturally sensitive to the diverse needs of community members and partners, starting with the selection and training of my University team members?

How can I prioritize considerations of diversity when designing, planning, and conducting my community-based research or program, identify any barriers to participation, and work to ameliorate or eliminate such barriers?

How will my actions reflect how the University is viewed in the community?

How do I manage, use and share resources of the University in a manner that is respectful to partners?

How do I teach and engage my students in the work of the community as they apply classroom learning to real world situations?

Patient Care Standards

Clinicians associated with the UConn Health, Storrs and regional campuses and other University health care facilities provide compassionate primary and specialty health care in an academic environment. We focus on delivering quality patient care and fostering continuous improvement through scientific knowledge that is shared with patients, colleagues and the public.

We, each faculty and staff member involved in patient-related activities, are expected to understand and support the applicable Patient’s Bill of Rights and Responsibilities.
We strive to deliver health care that is based on contemporary scientific knowledge and technology.
We provide educational resources and opportunity for consultations with other health care programs to assist our patients in the planning of their treatment.
We strive to consider the physical, emotional and spiritual needs of our patients in making our treatment recommendations.
We do not extend or receive payments or benefits in exchange for referrals. Our health care and referrals are based on the well-being of and best treatment for our patients.
Patients have a right to ask members of their health care team about the role of students and residents in their care and to receive complete and accurate information.We explain to our patients the importance of the educational mission at the University as it relates to their treatment.
We provide our patients with information necessary to make informed health care decisions. This includes reviewing medical findings with each patient, as well as discussing alternative treatment options and the associated risks and benefits.
We prepare clear, honest and accurate patient medical documentation in a timely manner. We maintain the confidentiality of this information in accordance with existing University policies and procedures, federal laws and state regulations, including but not limited to the Health Information Portability and Accountability Act (HIPAA).
We provide clinical facilities and laboratories to support quality care for our patients. We adhere to appropriate policies and procedures to ensure that we retain certification in all aspects of program function as required by institutional, state and federal regulatory agencies.

Questions to Ask Yourself

Do I demonstrate respect and compassion for my patients and their families?

Was the care that I provided today in the best interest of my patients?

Did I answer my patients’ questions to the best of my ability or assist them in obtaining the information they requested?

Do I offer all of the needed resources and services to my patients or assist them in making a referral to obtain those services?

Do I respect the privacy of my patients and protect the confidentiality of their health information?

Did I document my patient care thoroughly and accurately today?

Business, Fiscal and Legal Standards

The University of Connecticut adheres to established business standards in its conduct as an institution of higher education and as a health care provider. We comply with all applicable federal, state and local government laws and regulations and strive to follow ethical business practice standards. We endeavor to conduct all University business with honesty, integrity, accuracy and fairness.

Contracts

We strive to make all purchasing decisions based on the best interests of and value to the University. The University follows fair business practices in its contracting.
We recognize the value of obtaining competitive bids when appropriate, maintaining independence, ascertaining the financial and legal status of vendors and obtaining clear written agreements for services or goods to be purchased.
We comply with all state guidelines regarding procurement activities. We comply with all laws relating to pricing, competition and business arrangements.

Proprietary information

In the course of doing business, the University creates and receives information that could directly affect the success of its business ventures or those of its current or prospective business partners. If used inappropriately, this information could unduly benefit individuals who have access to such information. The University depends on the ethical business practices and personal integrity of its employees to protect this information from premature or improper use and disclosure.

Physical property and intellectual property, including data

The University’s physical property includes property that is owned by the University but entrusted to individuals or organizational units within the University. Examples include office and departmental equipment and supplies, vehicles, facilities, cash, reports and records, including clinical and billing records in department offices, computer software, electronic files and data, patents, trademarks and service marks.

We utilize such resources properly and protect property against loss, theft, misuse and waste.
Research materials, inventions or devices developed through the use of University resources are the property of the University. Rights to such property may be transferred to other parties (such as commercial sponsors) only with express written authorization. Materials subject to copyright are generally not the property of the University.
Research data are considered the property of the principal investigator or the joint property of collaborating individuals when research data are generated by a principal investigator working in collaboration with one or more faculty colleagues. Research data generated by postdoctoral fellows, graduate students, research trainees or others who have had significant intellectual input, shall be considered the joint property of the collaborating individuals.

The use of any form of intellectual property covered by copyright and license agreements and used for face-to-face, distance teaching purposes or a combination of the two, will comply with copyright law and the terms of the license agreement under which it was obtained. Examples include books, journal articles, newspapers, images, audio, and video in physical or electronic form owned or borrowed by the University or the instructor.

Financial Records and Funding Sources

We understand that the federal and state governments constitute major funding sources for the University in student financial aid, research and other areas. As such, we acknowledge responsibility for the stewardship of such funds, understanding and complying with federal and state laws and regulations.

We maintain accurate and timely financial records in accordance with the University’s policies and Generally Accepted Accounting Principles. We use appropriate internal financial controls to safeguard assets and to ensure compliance with all internal and external accounting rules and regulations. We cooperate fully with internal and external auditors and regulatory agencies during examinations of all books and records and do not alter or destroy any documents in anticipation of such reviews.
We, as employees of the University, accurately account for our time and properly document when seeking reimbursement for work-related expenses.
We charge and bill for patient care services in accordance with third party regulations and applicable state and federal laws. We bill for medically appropriate services that are clearly and accurately documented in the medical record. We submit claims for services in a timely manner. We maintain accurate patient accounts and promptly correct billing errors.
We acknowledge that clinical care providers, coding personnel and billing staff have a collective responsibility to understand the third party regulations and federal and state laws governing the services they are providing.

Questions to Ask Yourself

Did I document my work clearly, honestly and accurately?

When I sign a document do I understand what I am signing?

Do I understand when the competitive bidding process must be used?

Have I signed a contract without obtaining proper authorization?

Am I wasteful of university supplies?

Was I honest with my coding of patient visits today?

Do I share my computer password with others?

External Relations and University Advancement

Government relations and political activity

We depend, as a public institution, upon the support and trust of federal and state officials.

We will not make representations on behalf of the University without official authorization.
We do not engage in partisan political activities while on state time nor will we use University resources for the purposes of influencing a political election.
We adhere to federal and state laws which provide guidance for the political activities of the University employees.

Public access to University information

We facilitate accurate, ethical and timely news coverage of significant programs and the achievements of faculty, administrators, staff, students and alumni.
We comply with all federal and state laws and regulations as well as all University polices regarding the release of information about activities of the University, or its employees, students, volunteers, patients or research subjects, carefully balancing privacy rights with the public’s interest.

University Advancement

We recognize that the process of raising charitable funds requires ethical and sensitive interactions with prospective and current donors. Although we may release general information about alumni or other supporters, we respect an individual donor’s intent and honor all requests for anonymity.

We recognize that the primary responsibility for development of prospective donors lies with the University of Connecticut Foundation. The Foundation staff works in cooperation with offices and departments across the University but which is organizationally independent of the University itself.

Media Relations

We acknowledge that University Communications is the University’s primary and official liaisons to the news media – international, national, regional, state and local – and that this department is responsible for initiating, developing and maintaining effective, productive and beneficial relations with the news media in communicating University news and in responding to media requests.

We respect the individual freedom of faculty, staff and administrators to express their personal opinions on University actions and policies, while also recognizing that University Communications is responsible for coordinating official University comment on all matters regarding the institution.
We understand that the University encourages its faculty, staff and administrators to serve as members of community panels, boards, civic organizations, professional associations and other similar voluntary associations. An employee assuming such a role is not acting as a spokesperson of the University.

Graphic Standards

We recognize that University Communications is responsible for establishing and maintaining the University’s graphic standards and that specific standards apply to the use of the University’s logos and seals.
We understand that the University has legal rights regarding the use of its name, logos and seals and protected trademarks.

Questions to Ask Yourself

Have I referred media requests to University Communications?

Should I talk “off the record” to a reporter?

When is it appropriate to talk to the media about my research or to comment on the research of others?

Should I speak on behalf of the University to government officials regarding University mattersCan I be identified as a University employee in my political or charitable activities?

Do I maintain clear boundaries between my professional role and my personal activities that are unrelated to the University?

Resources, Additional Information and Reporting

The University has established the Office of University Compliance and Office of Audit & Management Advisory Services to oversee its internal audit and compliance programs and to ensure compliance with applicable laws, regulations, policies and procedures.

Obtaining Additional Information, Reporting Compliance Concerns and Non-retaliation Policy

For additional information please refer to the appropriate website or contact the office at the phone numbers or email addresses noted below. If you wish to report suspected violations of laws, regulations, rules, policies, procedures, ethics or any other information you feel uncomfortable reporting to your supervisor or faculty administrator you may also contact the Office of University Compliance directly using the phone numbers or email addresses listed below.

Storrs and Regional Campuses:

Website: https://compliance.uconn.edu/
Phone: (860) 486-2530
Fax: (860) 486-4527

UConn Health:

Website: https://compliance.uconn.edu/
Phone: (860) 679-1969

If you wish to report a concern or a suspected violation anonymously you may contact the University’s REPORTLINE using the contact information below. The REPORTLINE is operated by a private (non-University) company. No effort is made to identify the person reporting and no trace of the call is performed. Information received is given to the Compliance Officer for appropriate action. This service is available 24 hours a day, 7 days a week and is staffed by independent specialists trained to obtain complete and accurate information in a confidential manner. If you wish, you may obtain information about the Compliance Office response to your call by following up with the REPORTLINE at a later date. To contact the REPORTLINE:

Storrs and Regional Campuses Phone: 1-888-685-2637	UConn Health Phone: 1-888-685-2637
Web reporting address: https://www.compliance-helpline.com/uconncares.jsp

Other Reporting Options

State Auditors of Public Accounts

The Whistle Blower Act, Section 4-61dd of the Connecticut General Statutes, authorizes the Auditors of Public Accounts to receive information concerning matters involving corruption, unethical practices, violation of State laws or regulations, mismanagement, gross waste of funds, abuse of authority or danger to the public safety occurring in any State department or agency. Upon receiving such information the Auditors are required to review such matter and report their findings and any recommendations to the Attorney General.The Auditors shall not, after receipt of any information from a person under the provisions of this section, disclose the identity of such person without his/her consent unless the Auditors determine that such disclosure is unavoidable during the course of the review. You can file a complaint with the Auditors of Public Accounts by calling (860) 566-1435 or toll free at (800) 797-1702. Website: https://www.cga.ct.gov/apa/

Federal False Claims Act (31 U.S.C. § 3729-3733)

This act permits a person with knowledge of fraud against the federal government to file a lawsuit on behalf of the government against those that committed the fraud. The person filing the lawsuit is also known as the “whistleblower” or “qui tam” plaintiff. The “qui tam” plaintiff must notify the United States Department of Justice (DOJ) of all information regarding the fraud. If the DOJ takes the case and fraud is proven the “qui tam” plaintiff is entitled to a portion of the money recovered by the federal government. Under the False Claims Act the “qui tam” plaintiff is protected from retaliation that may result from his or her involvement in the case. This is known as Whistleblower Protection.

Non-Retaliation

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. If you feel that you have been subject to retaliation, you should contact the Compliance Office immediately. The Compliance Office will respond to all reports in a timely manner in order to resolve any non-compliance and to educate regarding compliance concerns.

Policy Created*: April 11, 2006

Policy Revisions*: 2/22/2011

*Approved by the Board of Trustees.

PURPOSE

DEFINITIONS

POLICY STATEMENT

PROCEDURES

I. New University Policy

II. Revising a University Policy

III. Decommissioning a University Policy

IV. Archiving a University Policy

V. Expedited (Emergency) Policy Approvals

REFERENCES

POLICY HISTORY

PURPOSE

CONFLICT OF INTEREST

POLITICAL ACTIVITY

MISCELLANEOUS: POST-EMPLOYMENT (REVOLVING DOOR) AND VENDOR NOTIFICATION

IMPORTANT ETHICS REFERENCE MATERIALS

POLICY HISTORY

PURPOSE

POLICY

PROCEDURE

POLICY HISTORY

Table of Contents

Letter from the President

The University of Connecticut Ethics Statement

Campus-Wide Standards

Education Standards

Research Principles and Standards

Public Engagement and Outreach Standards

Patient Care Standards

Business, Fiscal and Legal Standards

External Relations and University Advancement

Resources, Additional Information and Reporting