Office of University Compliance

University Policy on Policies

Posted on April 7, 2022July 7, 2026 by Quiles, Anida

Title:	Policy on Policies
Policy Owner:	Office of University Compliance
Applies to:	University Workforce Members
Campus Applicability:	All UConn Campuses, except UConn Health
Approval Date:	April 20, 2026
Effective Date:	June 15, 2026
For More Information, Contact:	Director of Policy, Office of University Compliance
Contact Information:	policy@uconn.edu
Official Website:	https://policy.uconn.edu

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. Committees may advise on content or participate in review processes, but they cannot serve as Policy Owners.

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 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 school, college, center or department policies (“unit policies”), must be vetted through the appropriate Dean or Director to ensure consistent application and to avoid conflict with any University or unit policies. Final approval must be from the Provost or other appropriate Vice President. Units should use a similar policy review process as outlined in this document. Please contact University Compliance or refer to the Policy website for assistance.

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. Additional information, such as membership, can be found on the Senior Policy Council page of the University Policies website.

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 with notification to the Board of Trustees, as appropriate.

Units of the University may establish policies within the scope of their delegated authority, provided such policies are consistent with and subordinate to University Policies. Unit-level policies, procedures, and guidelines shall not supersede, contradict, or otherwise diminish the requirements of 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
VI. Managing and Revising Procedures

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 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];
- must meet the requirements of the Policy Submission Checklist; and
- must 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 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;
- 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 the Policy Submission Checklist to University Compliance at policy@uconn.edu. The OUC 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. Policies that apply to UConn Health must be approved through that campus.
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 Policy Manager at UConn Health when appropriate).
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.

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, who will notify 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 SIO shall confer with applicable University governance groups and subject matter experts as appropriate to ensure overall impact is considered. The SIO 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 of decommissioned policies at the next scheduled Council meeting.

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 shorter 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.

VI. Managing and Revising Procedures

Procedures are enforceable operational requirements and so must be formally maintained in a manner that supports auditability, version control, and historical reference. Procedures must not consist solely of links to external websites, webpages, or system content without maintained document history. Instead, Procedures must be embedded within the policy or, if lengthy or operationally detailed, maintained as a separate attendant document with its own approval and revision history.

Protection of Minors and Reporting of Child Abuse and Neglect Policy

Posted on March 29, 2016February 20, 2026 by Laurie Neal

Title:	Protection of Minors and Reporting of Child Abuse and Neglect, Policy on
Policy Owner:	Office of University Compliance
Applies to:	All personnel associated with the University including faculty, staff, volunteers, graduate and undergraduate students, interns, residents and fellows.
Campus Applicability:	All UConn Campuses
Approval Date:	April 2, 2025
Effective Date:	April 2, 2025
For More Information, Contact	Compliance and Youth Protection Coordinator/Office of University Compliance
Contact Information:	minorprotection@uconn.edu or (860) 486-2530
Official Website:	https://compliance.uconn.edu/minor-protection/

Reason for Policy

The University of Connecticut is committed to promoting a high quality, secure and safe environment for minors who are active in the University community. This policy and the accompanying procedures establish consistent standards intended to support the University in meeting its commitments to promote protection of minors who participate in activities sponsored by the University and to inform all members of the University community of their obligation to report any instances of known or suspected child abuse or neglect.

Applies to

This policy applies to all University employees, including faculty, staff, volunteers, graduate and undergraduate students, interns, residents and fellows. Except as provided below, it also applies to any activity that takes place on University property or is sponsored by the University and is open to the participation of minors.

This policy does not apply to: (1) events open to the public where parents/guardians or adult chaperones are expected to accompany and supervise their children; (2) undergraduate and graduate programs in which minors are enrolled for academic credit or have been accepted for enrollment for academic credit; (3) students who are dually enrolled in University credit-bearing courses while also enrolled in elementary, middle, and/or high school, UNLESS such enrollment includes overnight housing in University facilities; (4) minors employed by the University; (5) field trips or visits to the University that are solely supervised by a minor’s school or organization; (6) patient-care related activities relating to minors; (7) non-University programs undertaking activities in or on University land or facilities under the sole supervision of said program; (8) University programs that take place outside of the University under the supervision of a separate organization; (9) licensed child care facilities; (10) Institutional Review Board (IRB) approved research; and (11) other activities granted advance and written exemption from part or all of this policy.

Definitions [1]

A. Authorized Adult: A University employee, student, or volunteer (paid or unpaid) who has (1) successfully passed a Background Screening within the last four years, (2) completed the University minor’s protection training within the last year, and (3) has been registered with the University’s Minor Protection Coordinator.

B. University Sponsored Activities Involving Minors: A program or activity open to the participation of minors that is sponsored, operated, or supported by the University and where minors, who are not enrolled or accepted for enrollment in credit-granting courses at the University or who are not an employee of the University, are under the supervision of the University or its representatives.

C. Background Screening: A criminal history search that is consistent with University criminal background check policies and that has been successfully completed within the past four years. Such criminal history search must include the following searches by a nationally recognized background check vendor:

i. Social Security Number verification/past address trace;

ii. federal criminal history record search for felony and misdemeanor convictions covering, at minimum, the last seven years in all states lived in;

iii. a statewide or county level criminal history record search for felony and misdemeanor convictions covering, at minimum, the last seven years in all states lived in; an;

iv. sex offender registry searches at the county level in every jurisdiction where the candidate currently resides or has resided.

D. Child Abuse: A non-accidental physical injury to a minor, or an injury that is inconsistent with the history given of it, or a condition resulting in maltreatment. Examples include but are not limited to, malnutrition, sexual molestation or exploitation, deprivation of necessities, emotional maltreatment, or cruel punishment.

E. Child Neglect: The abandonment or denial of proper care and attention (physically, emotionally, or morally) of a minor, or the permitting of a minor to live under conditions, circumstances, or associations injurious to the minor’s well-being.

F. Minor: Any individual under the age of 18, who has not been legally emancipated.

G. Mandated Reporter: An individual designated by the Connecticut law as required to report or cause a report to be made of Child Abuse or Child Neglect. All employees of the University, except student employees, are Mandated Reporters under state law.

H. Minor Protection Coordinator: An individual designated by the University to develop procedures to implement this policy and best practices for the protection of minors involved in University Sponsored Activities Involving Minors, and to provide coordination, training, and monitoring in order to promote the effective implementation of this policy.

Reporting Child Abuse/Neglect

Pursuant to state law, all University employees (except student employees) are Mandated Reporters of Child Abuse and/or Child Neglect and must comply with the reporting requirements in Connecticut’s mandated reporting laws. See Conn. Gen. Stat. §§17a-101a to 17a-101d.

Connecticut state law, requires that reports of known or suspected child abuse or neglect be made orally, as soon as possible (but no later than 12 hours), to law enforcement or the Connecticut Department of Children and Families (DCF), and followed up in writing within 48 hours.

DCF’s 24-hour hotline for reporting suspected Child Abuse or Child Neglect is (800) 842-2288, and additional guidance on these reporting requirements may be found here:

https://portal.ct.gov/DCF/1-DCF/Reporting-Child-Abuse-and-Neglect (Last accessed July 23, 2018).

University employees are protected under state law for the good faith reporting of suspected Child Abuse or Child Neglect, even if a later investigation fails to substantiate the allegations.

In addition to this statutory reporting requirement, University employees must also comply with any other University policies that impose additional reporting obligations, such as the Policy Against Discrimination, Harassment, and Related Interpersonal Violence.

Requirements for University Sponsored Activities Involving Minors

To better protect Minors participating in activities sponsored by the University, all University Sponsored Activities Involving Minors must meet the following requirements, in addition to any applicable federal, state, or local law, and all University policies. Please Note: A more comprehensive description of the following requirements are detailed in the accompanying procedures.

A. University Sponsored Activities Involving Minors must register with the University’s Minor Protection Coordinator with sufficient advance notice to confirm the requirements of this policy have been met.

B. No individual, paid or unpaid, shall be allowed to supervise, chaperone, or otherwise oversee any Minor who participates in University Sponsored Activities Involving Minors unless he or she is an Authorized Adult.

C. All University Sponsored Activities Involving Minors must implement standards to safeguard the welfare of participating Minors. At minimum, all University Sponsored Activities Involving Minors must implement and comply with University standards of conduct included in the accompanying procedures.

D. All University Sponsored Activities Involving Minors are subject to periodic audits to verify compliance with this policy and the accompanying procedures.

E. Any exceptions to these requirements must be requested with sufficient notice and approved in writing by the Minor Protection Coordinator, in consultation with Minor Protection Oversight Committee prior to the start of program operations.

Enforcement

Violations of this policy and accompanying procedures 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 applicable Student Code.

Policy History

Policy Created: April 1, 2016 [Approved by the President's Cabinet]

Revisions:
August 9, 2018
April 2, 2025 [Approved by Senior Policy Council]

Procedures

Procedures for the Protection of Minors and Reporting of Child Abuse and Neglect

Footnotes

[1] Several of these definitions are adapted in whole or in part from the Connecticut General Statutes. See Conn. Gen. Stat. § 120. For additional guidance from the Connecticut Department of Children and Family Services about the definitions of child abuse and neglect, see https://portal.ct.gov/DCF/1-DCF/Reporting-Child-Abuse-and-Neglect. (Last accessed 7/23/2018.) Back

HIPAA- Health Insurance Portability and Accountability Act

Posted on May 20, 2015July 1, 2026 by Laurie Neal

The University’s Privacy Officer maintains a separate website providing access to HIPAA related resources, including policies, procedures, and forms.

Please note that the resources at hipaa.uconn.edu apply to HIPAA practices on the Storrs and Regional Campuses. If you are interested in learning more about HIPAA practices at the University of Connecticut Health Center and its affiliates, please visit UConn Health.

Use of Students in Outside Employment

Posted on June 2, 2011April 1, 2026 by Fearney, Kimberly

Title:	Use of Students in Outside Employment
Policy Owner:	Office of University Compliance
Applies to:	All Employees
Campus Applicability:	All UConn Campuses
Approval Date:	March 19, 2026
Effective Date:	April 1, 2026
For More Information, Contact	Office of University Compliance
Contact Information:	(860) 486-2530 or universitycompliance@uconn.edu
Official Website:	https://compliance.uconn.edu/

BACKGROUND

Involvement of students in the outside professional activities of employees may, under certain conditions, offer the potential for substantial benefits to the education of our students. While these relationships may have educational value for the student, they also have the potential for conflicts of interest. The Code of Ethics for Public Officials precludes public employees from accepting other employment which may impair the employee’s independence of judgment or otherwise create a conflict of interest.

PURPOSE

To define requirements for University employees who seek to hire or engage in a business relationship with students for activities external to the University, including both for profit and not for profit activities.

APPLIES TO

All employees

DEFINITIONS

Business Relationship: A formal association between two or more parties based on mutual economic or organizational interests that include, but are not limited to, equity ownership, voting rights or membership in an LLC. This also includes interests in any company that participates in the University’s Technology Incubation Program (TIP).

POLICY STATEMENT

Potential conflicts of interest may occur when a University employee hires or enters into a business relationship with a student in any non-University activity. Therefore, employees who wish to employ or enter into a business relationship with students in any non-University activity must obtain written approval from their Department Head/Dean/Director prior to entering into the arrangement. Employees who wish to employ or enter into a business relationship with a student who they advise or supervise in their University role must receive additional approval from the next level of management above their Department Head/Dean/Director to manage the inherent power difference present in such an arrangement.

Faculty members who wish to hire a 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 director of the student’s thesis or dissertation research, must also receive written approval from the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students). Faculty members in these cases are not permitted to enter into a business relationship with a student until after the student has graduated or has otherwise left the University.

Until such time as the employment or business relationship ceases, for the protection of students who may participate in research involving a faculty member’s business or whose work on a thesis or dissertation draws from the faculty member’s business data or research, the student shall have a second (joint or primary) advisor who is not affiliated in any way with the outside employment.

The University requires that the university employee who hires a student for a non-University activity execute a written Employment Agreement with the student and which includes a specific scope of work or job description, the rate of compensation, and the expected hours of work. The scope of work in the business or startup should be different from and have no overlap with the student’s thesis or course-based project work.

The student’s external engagement as an employee should not interfere with the student’s class time and participation in university course work or delay his/her completion of degree. Students must be provided with information about their rights under this policy at the beginning of their employment or business relationship. In addition, the employed student must receive a fair market value rate of pay.

Students have the option to discontinue their employment or business relationship at any point with no repercussion, with a recommended best practice of providing appropriate advanced notice. The university employee may not retaliate against a student for the student’s decision to depart from employment or business relationship. Students who feel they have been aggrieved or otherwise have concerns that arise during their term of employment or beyond employment after they may decide to leave may go to the Provost to address their issue. The issues should be documented and substantiated with evidence. When addressing potential issues regarding the non-University employment of students, or student-employee business relationships, the Provost will consult with the Dean of the Graduate School (for graduate students) or the Vice Provost for Academic Affairs (for undergraduate students).

ENFORCEMENT

Violations of this policy and any related procedures 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 the University of Connecticut Student Code.

PROCEDURES/FORMS

Approval Form for Employee and Student Business Relationships
Use of Students in Outside Employment Letter Template

REFERENCES

Intellectual Property and Commercialization Policy

POLICY HISTORY

Policy created: 03/01/2004

Revisions:
06/23/2008
12/16/2014
07/13/2015
03/19/2026 (Approved by the University Senior Policy Council, President, and State of Connecticut Citizens Ethics Advisory Board)

Non-Retaliation Policy

Posted on May 24, 2011June 18, 2026 by Fearney, Kimberly

Title:	Non-Retaliation Policy
Policy Owner:	Office of the President
Applies to:	University Workforce Members, Students, Affiliated Persons
Campus Applicability:	All UConn Campuses
Approval Date:	November 19, 2025
Effective Date:	November 19, 2025
For More Information, Contact	Office of University Compliance
Contact Information:	universitycompliance@uconn.edu
Official Website:	https://compliance.uconn.edu

PURPOSE

To demonstrate the University of Connecticut’s responsibility and commitment to protecting individuals within the University Community from Retaliation. The University encourages community members to report suspected violations of University policy or applicable laws and reporters must be able to do so without the fear of Retaliation.

POLICY STATEMENT

The University strictly prohibits any form of Retaliation against individuals who engage in a Protected Activity as defined within this policy.

This policy does not extend protection to those who knowingly submit a Bad Faith Report.

DEFINITIONS

Retaliation: Any materially Adverse Action taken or threatened against an individual because of their actual or suspected participation in a Protected Activity or any action taken to discourage or prevent an individual from engaging in a Protected Activity.

Adverse Action: Any harmful or punitive measure intended to negatively impact an individual’s employment or academic standing, or an individual’s participation in University activities. Examples may include, but are not limited to:

termination, demotion, or interference with or denial of promotion or advancement opportunities (whether employment or academic);
reduction in grades or academic standing;
denial or removal of co-authorship on a publication;
poor performance evaluation or disciplinary action without substantiation;
exclusion from University programs or activities;
decisions related to the terms and conditions of employment or education that create a material disadvantage;
physical threats or destruction of personal or University property;
any form of harassment, intimidation, or discrimination including humiliation, derogatory or insulting remarks, or social isolation, whether direct or indirect.

Good Faith Report: A report made with an honest and reasonable belief that a violation of University policy or applicable law may have occurred, regardless of whether it is ultimately substantiated.

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

Protected Activity: A report made in good faith whether internally or externally; inquiring about suspected violation of policy or applicable law; opposing or refusing to engage in actual or perceived violations of policy or applicable law; assisting others in making a good faith report; and/or participating in an investigation, review, or proceeding related to such reports.

REPORTING PROCESS

If an individual believes they have been subjected to Retaliation, they should contact the office to which their 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: 1-888-685-2637 or compliance.uconn.edu/reporting-concerns/ Website: compliance.uconn.edu	The Office of University Compliance Administrative Services Building 263 Farmington Avenue Farmington, CT 06030-5329 Telephone: (860) 486-2530 Reportline: 1-888-685-2637 or compliance.uconn.edu/reporting-concerns/ Website: compliance.uconn.edu
The Office of Inclusion and Civil Rights (OICR) 241 Glenbrook Road Wood Hall, Unit 4175 Storrs, CT 06269-4175 Telephone: (860) 486-2943 Email: equity@uconn.edu OICR’s Discrimination Complaint Procedures: equity.uconn.edu/policiesprocedures/	The Office of Inclusion and Civil Rights (OICR) Munson Building 263 Farmington Avenue Farmington, CT 06030-5130 Telephone: (860) 679-3563 Email: equity@uconn.edu OICR’s Discrimination Complaint Procedures: equity.uconn.edu/policiesprocedures/
Labor Relations 9 Walters Avenue, Unit 5075 Storrs, CT 06269-5075 Telephone: (860) 486-5684 Website: hr.uconn.edu/labor-relations/	Labor Relations Munson Building 263 Farmington Avenue Farmington, CT 06030-4035 Telephone: 860-679-8067 Website: health.uconn.edu/human-resources/services/employee-labor-relations/

ADDITIONAL RESOURCES

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

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

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

Dean of Students Office
Website: https://dos.uconn.edu/

UConn Cultural Centers
Website: https://studentactivities.uconn.edu/cultural/

ENFORCEMENT

Violations of this policy or related procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees and/or Rules of Conduct, applicable collective bargaining agreements, the University of Connecticut Student Code, or resident/fellow codes of conduct.

POLICY HISTORY

Policy Created: 9/22/2009

Policy Revised:
10/22/2012 (No substantive revisions)
05/03/2021 (Approved by President’s Cabinet)
11/19/2025 (Approved by the Senior Policy Council and President)

Guide to the State Code of Ethics

Posted on May 24, 2011July 23, 2026 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 their 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:

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

Family Educational Rights and Privacy Act (FERPA) Policy

Posted on May 24, 2011September 1, 2026 by Fearney, Kimberly

Title:	FERPA Policy
Policy Owner:	Office of University Compliance
Applies to:	All University workforce members, students, and affiliates
Campus Applicability:	All UConn Campuses
Approval Date:	August 19, 2026
Effective Date:	August 31, 2026
For More Information, Contact	University Privacy Office
Contact Information:	privacy@uconn.edu
Official Website:	https://privacy.uconn.edu/

BACKGROUND

The Family Educational Rights and Privacy Act (FERPA) is a federal law that protects the privacy of student education records. FERPA governs access and disclosure of education records maintained by an educational institution and affords students with certain rights regarding their education records. The University is committed to maintaining the privacy of education records and ensuring these student rights in compliance with FERPA.

APPLIES TO

All University workforce members, students, and affiliates.

DEFINITIONS

Directory Information: Information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed.

Education Records: Records that are directly related to a student and maintained by the University or by a party acting for the University.

Legitimate Educational Interest: A school official has a legitimate educational interest if the official needs to review an education record in order to fulfill their professional responsibilities for the University.

School Official: A person employed by the University in an administrative, supervisory, academic, research, or support staff position (including law enforcement unit personnel and health staff); a person serving on the board of trustees; or a student serving on an official committee, such as a disciplinary or grievance committee. A school official also may include a volunteer or contractor outside of the University who performs an institutional service or function for which the school would otherwise use its own employees and who is under the direct control of the school with respect to the use and maintenance of personally identifiable information from education records, such as an attorney, auditor, collection agent, or a student volunteering to assist another school official in performing his or her tasks.

Student: Any person who is or has been in attendance at the University and regarding whom the University maintains education records. A person is considered to be in attendance at the University on the first day of classes for the program in which the person is enrolled.

POLICY STATEMENT

The University will ensure that students are afforded their rights under FERPA, including the right to inspect and review their education records, the right to request amendment of their education records, the right to limit disclosure of their education records, and the right to file a complaint concerning any alleged failure to comply with FERPA. In accordance with FERPA, the University has also designated certain categories of information, set forth in this policy, as Directory Information.

All University workforce members, students, and affiliates who have access to student education records are responsible for ensuring that such access, use, and disclosure is in compliance with FERPA and this Policy. Education records may be accessed only for legitimate educational purposes and may not be disclosed except as permitted by FERPA and this Policy.

A. Student Rights

FERPA affords students certain rights with respect to their education records. These rights include:

The right to inspect and review the student’s education records within 45 days after the day the University receives a request for access. A student should submit to the registrar, dean, department head, or other appropriate official, a written request that identifies the record(s) that the student wishes to inspect. The University official will make arrangements for access and notify the student of the time and place where the records may be inspected. If the records are not maintained by the University official to whom the request was submitted, that official shall advise the student of the correct official to whom the request should be addressed.
The right to request the amendment of the student’s education records that the student believes is inaccurate, misleading, or otherwise in violation of the student’s privacy rights under FERPA. A student who wishes to request an amendment of a record should write to the University official responsible for the record, clearly identify the part of the record the student wants changed, and specify why it should be changed. If the University decides not to amend the record as requested, the University will notify the student in writing of the decision and the student’s right to a hearing regarding the request for amendment. Additional information regarding the hearing procedures will be provided to the student when notified of the right to a hearing.
The right to provide written consent before the University discloses personally identifiable information from the student’s education records, except to the extent FERPA authorizes disclosure without consent. FERPA permits the disclosure of personally identifiable information from students’ education records, without consent of the student, if the disclosure meets one or more of the following conditions:

- To school officials with legitimate educational interests.
- To officials of another school in which a student seeks or intends to enroll, or where the student is already enrolled if the disclosure is for purposes related to the student’s enrollment or transfer. The University will forward those records without notification to the student.
- To authorized representatives of the U.S. Comptroller General, the U.S. Attorney General, the U.S. Secretary of Education, or State and local educational authorities, in connection with an audit or evaluation of Federal or State supported education programs, or for the enforcement of or compliance with Federal legal requirements that relate to those programs.
- In connection with financial aid for which the student has applied or which the student has received, if the information is necessary to determine eligibility for the aid, determine the amount of the aid, determine the conditions of the aid, or enforce the terms and conditions of the aid.
- To organizations conducting studies for, or on behalf of, the University, in order to: develop, validate, or administer predictive tests; administer student aid programs; or improve instruction.
- To accrediting organizations to carry out their accrediting functions.
- To comply with a judicial order or lawfully issued subpoena.
- To appropriate parties in connection with a health or safety emergency.
- Information the University has designated as “directory information.”
- To a victim of an alleged perpetrator of a crime of violence or a non-forcible sex offense. The disclosure may only include the final results of the disciplinary proceeding with respect to that alleged crime or offense, regardless of the finding.
- To the general public, the final results of a disciplinary proceeding, if the school determines the student is an alleged perpetrator of a crime of violence or non-forcible sex offense and the student has committed a violation of the school’s rules or policies with respect to the allegation made against them.
- To parents of a student regarding the student’s violation of any Federal, State, or local law, or of any rule or policy of the school governing the use or possession of alcohol or a controlled substance if the school determines the student committed a disciplinary violation and the student is under the age of 21.
- The disclosure concerns sex offenders and other individuals required to register under section 170101 of the Violent Crime Control and Law Enforcement Act of 1994.

The right to file a complaint with the U.S. Department of Education concerning alleged failures by the University to comply with the requirements of FERPA. The name and address of the office that administers FERPA is:

Student Privacy Policy Office
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202

B. Directory Information

FERPA authorizes the University to designate certain categories of information contained in education records as Directory Information and to disclose such information without prior consent, unless the student has opted-out of Directory Information in accordance with University procedures. The University has designated the following as Directory Information:

Name
NetID
PeopleSoft Number
School or College
Major Field of Study
Degree Sought
Class Level
Enrollment Status
Degrees, Honors & Awards Received
Residency/Match Information (Medical/Dental Students)
Dates of Attendance
Participation in Officially Recognized Activities and Sports
Weight, Height and Performance Statistics of Athletic Team Members
Photographic Likenesses and Video of Athletic Team Members
For Student Employees, Employing Department & Dates of Employment
Most Recent Educational Agency or Institution Attended

In addition, the University has designated the following as Limited Directory Information, the disclosure of which is limited to specific purposes and/or specific parties, as set forth below:

Photographs and Videos
Email Address
Mailing Address
Telephone Number
Date and Place of Birth

Limited Directory Information may only be used in official University publications or websites maintained by or on behalf of the University, including the University’s online directory and internal email system; or disclosed only to specific parties limited to the UConn Foundation and the UConn Law School Foundation.

Students may opt-out of their Directory Information being shared with third parties, except to the extent FERPA authorizes disclosure without consent, as set forth above. Students who would like to opt-out of their Directory Information being shared must make the request in writing.

At the Storrs and Regional Campuses, all requests must be directed to the One Stop Student Services, Wilbur Cross Building, Room 104, Storrs, CT 06269-4077, or onestop@uconn.edu.

At UConn Health, all requests must be directed to the Office of the Registrar, Student Services Center, 263 Farmington Avenue, Farmington, CT 06030-1826, or registrar@uchc.edu.

At the UConn Law School, all requests must be directed to the Office of the Registrar, Thomas J. Meskill Law Library, 39 Elizabeth Street, Room 211, Hartford, CT 06105, or law.registrar@uconn.edu

An opt-out of Directory Information will remain in effect until removed by written request of the student. Students who opt-out of Directory Information will be deemed to opt-out of Limited Directory Information.

ENFORCEMENT

Violations of this policy 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 the University of Connecticut Student Code.

PROCEDURES

FERPA Privacy Rights Procedures

REFERENCES

Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. §1232g; 34 CFR Part 99.

POLICY HISTORY

Policy created: 08/01/2007

Revisions:
02/01/2010
02/06/2013
02/13/2015
08/2016
01/19/2021
08/31/2026 (Approved by the University Senior Policy Council and President)

Employment and Contracting for Service of Relatives, Policy on

Posted on May 24, 2011September 9, 2026 by Fearney, Kimberly

Title:	Employment and Contracting for Service of Relatives, Policy on
Policy Owner:	Office of University Compliance and Human Resources
Applies to:	Faculty, Staff, Students
Campus Applicability:	All UConn Campuses
Approval Date:	August 21, 2026
Effective Date:	August 31, 2026
For More Information, Contact:	Office of University Compliance and Human Resources, Labor Relations
Contact Information:	UConn Health: (860) 679-4180 or (860) 679-2426 UConn Storrs/Storrs Based Campuses: (860) 486-2530 or (860) 486-5684
Official Website:	https://compliance.uconn.edu/conflicts-of-interest/ or https://hr.uconn.edu/labor-relations/

BACKGROUND

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.

PURPOSE

To protect against conflicts and complaints concerning disparate treatment and favoritism, and to provide for the ethical and legally consistent treatment of individuals with relatives seeking employment or who are employed by the University.

APPLIES TO

Faculty, staff, and students on all campuses

DEFINITIONS

Relative: Defined in this policy as a 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.

Direct Supervisor: An employee’s immediate manager or supervisor.

Indirect Supervisor: Any person above an employee’s direct supervisor in the employee’s reporting chain.

POLICY STATEMENT

No employee of the University of Connecticut may be the direct or Indirect Supervisor of or take any action which would affect the financial interests of one’s Relative. This may include, but not limited to, 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 their position to influence an employment action of a non-Relative if such action would benefit one’s Relative.

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

ENFORCEMENT

PROCEDURES/FORMS

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 submitting the Conflict of Interest (COI) Disclosure Form.
The COI Disclosure Form is submitted through the supervisory chain and at a minimum must be approved by a dean/department head/director (DDD). If the employee’s direct supervisor is a DDD, then the COI Disclosure Form must be approved by the next appropriate senior manager. Using the COI Disclosure form, the employee’s direct supervisor shall propose to their 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 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 COI is then routed through Human Resources for processing purposes and shall be reviewed with the Office of University Compliance for consultation on the appropriateness and effectiveness of the mitigation plan. Any additional recommendations will be made at the time of this review.
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.

REFERENCES

Conflict of Interest (COI) Disclosure Form

POLICY HISTORY

Policy created: 11/09/2010 (Approved by the Board of Trustees)

Revisions:
08/21/2026 (Approved by the University Senior Policy Council and President)

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

Posted on May 17, 2011February 17, 2026 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, 2011February 17, 2026 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
Approval Date:	June 27, 2024
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.