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Governing and Cost Accounting Standards

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Title: Governing and Cost Accounting Standards
Policy Owner: Office of the Vice President for Research, Sponsored Program Services
Applies to: All Faculty, Staff, and Students
Campus Applicability: All campuses
Effective Date: November 18, 2019
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: 860-486-3622 (Storrs and regional campuses)

860-679-4040 (UConn Health)
Official Website: https://ovpr.uconn.edu (Storrs and regional campuses)

https://ovpr.uchc.edu (UConn Health)

REASON FOR POLICY

To confirm sponsored programs are administered in accordance with award requirements such as the Uniform Guidance, Cost Accounting Standards for Educational Institutions, Federal Acquisition Regulations, Federal and State regulations, and sponsor and university policies.

APPLIES TO

All faculty, staff, and students involved in the administration of sponsored programs at the University of Connecticut, regional campuses, and UConn Health (“University”).

POLICY STATEMENT

This policy establishes the terms and conditions that govern sponsored projects.  The University will be responsible for determining the appropriate costing treatment and for the maintenance of the CAS Disclosure Statement (DS-2) as prescribed in 2 C.F.R. §200.419.

In accepting a sponsored program, the Institution and Principal Investigator(s) assume responsibility for fulfilling the requirements of the program.  These requirements may be specifically contained in the agreement or they may be incorporated by reference to guidelines issued by the sponsor in special publications or directives.

Cost accounting and financial compliance for federally funded sponsored projects at the University is dictated by various Federal Office of Management and Budget Circulars and agency regulations.

The following is a brief explanation of the major bodies of federal and agency regulations that address financial compliance related to sponsored programs:

Uniform Guidance (2 CFR Part 200)

The Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) establishes a basis for policy in the management of federally sponsored programs.

Specifically, the Uniform Guidance sets forth the uniform administrative requirements for grant and cooperative agreements, including the requirements for Federal awarding agency management of Federal grant programs before the Federal award has been made, and the requirements Federal awarding agencies may impose on non-Federal entities in the Federal Award. The Uniform Guidance also establishes the principles for determining the allowable costs incurred by non-Federal entities under Federal awards. Finally, the Uniform Guidance sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards.

Federal Acquisitions Regulations (FAR) (48 CFR)
Establishes the policies, procedures, and requirements of Federal contracts.

Cost Accounting Standards (48 CFR 9905)

Standards designed to ensure uniformity and consistency in the measurement, assignment and allocation of costs to contracts with the US Federal Government, and include:

CAS 501 – Consistency in Estimating, Accumulating and Reporting Costs

University will ensure compliance by employing consistent practices when developing budgets for proposals and in accounting and reporting costs for program expenses (in accordance with Federal and State rules and regulations and University policy).

CAS 502 – Consistency in Allocating Costs Incurred for the Same Purpose

Costs incurred for the same purpose, in similar circumstances, must be given consistent treatment in the accounting system. All costs must be charged consistently as either a direct cost or as part of the federally negotiated Facilities & Administrative (F&A) cost structure.

CAS 505 – Accounting for Unallowable Costs

Unallowable costs (as defined by federal, state or university regulation or policy) must be identified and excluded from any billing, claim, or proposal submitted to the Federal government.

CAS 506 – Cost Accounting Period

The University Fiscal Year (July 1 – June 30) will be used as the accounting period regardless of the sponsor’s accounting period.

Federal Sponsor Guidelines
While the Uniform Guidance establishes the principles for sponsored program management, each federal agency may differ in policy application. Additionally, terms and conditions specific to an award may apply.

Non-Federal Sponsor Guidelines
The specific award agreement, together with University policy, usually guides the project’s conduct.  State agencies, foundations, and private businesses may also publish their own funding guidelines and requirements.

ROLES AND RESPONSIBILITIES

Principal Investigator

Responsible for ensuring appropriateness of all charges on sponsored projects.  Ensure the consistent application of direct costing practices to sponsored projects.

Department or Shared Services Fiscal Officer/ Administrator

Assists the Principal Investigator in ensuring consistent application of costing practices, record keeping and other financial and administrative requirements.

Sponsored Program Services

Develop and maintain policies and procedures in accordance with Federal regulations.  Provide training and guidance to Principal Investigators and staff.  In accordance with policy and procedure, review transactions for appropriateness under Federal and institutional guidelines.

Office of Cost Analysis (Storrs and regional campuses) / Research Finance (UConn Health)

Maintain and file CAS Disclosure Statement (DS-2) in accordance with §200.419 identifying accounting practices, policies, and procedures for assigning costs to federally sponsored programs, and to attest to the consistent treatment of those practices.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for all University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.

 

PROCEDURES/FORMS/ OTHER POLICY

UConn Storrs and Regional Campuses:

Disclosure Statement (DS-2)

Cost Accounting Disclosure-1 Direct/Indirect

 

UConn Health:

UCH Policy 2002-39:  Direct Cost Expenditures

UCH Policy 2002-05:  Unallowable Costs/Administrative Costs

Disclosure Statement (DS-2)

 

POLICY HISTORY

Policy created:  Approved by the President’s Cabinet on 09/12/2019. This is a new University wide policy to better document practices at Storrs and regional campuses and combines two previous policies at UConn Health.

History:                

Miscellaneous guidance at Storrs and regional campuses

UCH Policy 2002-12, “Governing Standards”, 2/25/2002

UCH Policy 2002-37, “Cost Accounting Standards”, 2/25/2002

 

UConn’s NAGPRA Procedure

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University of Connecticut NAGPRA Procedures:

The Provost will designate one or more persons at the University to help administer the University’s compliance obligations under NAGPRA.  That person(s) is referred to as the “NAGPRA Coordinator(s)” for purposes of these procedures. The NAGPRA Coordinator will be responsible for working in close consultation with lineal descendants and Native American and Native Hawaiian organizations in identifying any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony that are maintained by the University, and on determinations of cultural affiliation and repatriation of Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony, that are part of the University’s collections.

NAGPRA Review Group

The Provost will establish a NAGPRA review group to assist the NAGPRA Coordinator in the administration of the University’s compliance obligations under NAGPRA and to report recommendations on cultural affiliation and repatriation to the Provost.  This review group will be chaired by an appointee designated by the Provost and will include the State Archaeologist, members from the Department of Anthropology and the Connecticut State Museum of Natural History and other offices at the University who maintain human remains, funerary objects, sacred objects, or objects of cultural patrimony.  The representatives of the review committee will be responsible for communicating and involving the departments, museums and other University offices they represent on matters relating to the University’s compliance obligations under NAGPRA.

Use of Human Remains in Teaching and Research

The NAGPRA review group must be notified of any teaching or research being conducted at the University or by faculty or staff from the University that involves the use of Native American or Native Hawaiian human remains.

NAGPRA Collections

The NAGPRA Coordinator will work with the NAGPRA review group and departments, museums and other University offices to help maintain a centralized record of all Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University, such record will include the location(s) of the relevant items and any NAGPRA-related reports or communications relating to such items.

NAGPRA Reporting & Process Initiation

The NAGPRA Coordinator will inform the NAGPRA review group and the Provost upon becoming aware of any Native American and Native Hawaiian human remains and cultural items maintained by the University that were not previously reported under NAGPRA.  The NAGPRA Coordinator will initiate a NAGPRA process for any Native American and Native Hawaiian human remains and cultural items maintained by the University.  This will include consulting with lineal descendants and Native American and Native Hawaiian organizations prior to making any recommendation as to cultural affiliation or repatriation.  The NAGPRA Coordinator must consult with the NAGPRA review group and the Provost’s office prior to completing a summary or inventory under NAGPRA.

Cultural Affiliation Recommendations

The NAGPRA Coordinator will make a proposed recommendation of cultural affiliation, when appropriate, for any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University to the NAGPRA review group.  The NAGPRA review group will review and evaluate such recommendations.

The chair of the NAGPRA review group will submit a proposed recommendation of cultural affiliation, reflecting the initial recommendation provided by the NAGPRA Coordinator and the comments of the NAGPRA review group, to the Provost.  The Provost is the only University official authorized to make determinations of cultural affiliation under NAGPRA with respect to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University.

Repatriation Recommendations

The NAGPRA Coordinator will be responsible for identifying appropriate claimant(s) and making a proposed recommendation of repatriation, when appropriate, for any Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University to the NAGPRA review group.  The NAGPRA review group will review and evaluate such recommendations.

The chair of the NAGPRA review group will submit a proposed recommendation of repatriation, reflecting the initial recommendation provided by the NAGPRA Coordinator and the comments of the NAGPRA review group, to the Provost.  The Provost is the only University official authorized to make a recommendation of repatriation under NAGPRA with respect to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony maintained by the University.

Native American Graves Protection and Repatriation Act Policy

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Title: Native American Graves Protection and Repatriation Act Policy
Policy Owner: Office of the Provost
Applies to: Faculty, Staff, Others
Campus Applicability: All campuses, including UConn Health
Effective Date: April 24, 2019
For More Information, Contact University NAGPRA Coordinator
Contact Information: (860) 486-6953
Official Website: https://provost.uconn.edu/

Reason for Policy:

The purpose of this policy is to ensure that Native American and Native Hawaiian human remains and funerary objects, sacred objects, and objects of cultural patrimony are maintained and repatriated by the University in a respectful, dignified and legally compliant manner as required by the Native American Graves Protection and Repatriation Act (“NAGPRA”).  Only items subject to the requirements of NAGPRA are subject to this policy.

Applies to:

Faculty, Staff, Others

Definitions:

This policy references the terms below and uses the definitions that have been assigned to those terms by NAGPRA in 25 U.S.C. §§ 3001–3013 and 43 C.F.R. pt. 10 (as summarized below).

Human remains means physical remains of the body of a person of Native American or Native Hawaiian ancestry.  The University considers human remains to include DNA and other biological derivatives obtained from the body of a person of Native American or Native Hawaiian ancestry.

Funerary objects means items that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed intentionally at the time of death or later with or near individual human remains.

Sacred objects means items that are specific ceremonial objects needed by traditional Native American religious leaders for the practice of traditional Native American or Native Hawaiian religions by their present-day adherents.

Objects of cultural patrimony means items having ongoing historical, traditional, or cultural importance central to the Native American or Native Hawaiian organization itself, rather than property owned by an individual organization member.

Policy Statement:

The University is committed to working with lineal descendants and Native American and Native Hawaiian organizations, both federally and non-federally recognized, with respect to determinations of cultural affiliation and repatriation of Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony that are part of the University’s collections.  The University is committed to ensuring that all such human remains and cultural items that are part of its collections are appropriately identified and treated with respect during that process.  The University welcomes all Native peoples to campus for NAGPRA consultation.

NAGPRA requires that the University follow a process for reporting information relating to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony, that are part of the University’s collections.

NAGPRA also requires that the University notify and consult with lineal descendants and Native American and Native Hawaiian organizations on human remains, funerary objects, sacred objects, and objects of cultural patrimony.

All University personnel must assist the University in fulfilling its legal obligations under NAGPRA.  The Provost will be responsible for designating one or more persons at the University to administer the University’s compliance obligations under NAGPRA and for ensuring that the University appropriately maintains and repatriates human remains, funerary objects, sacred objects, and objects of cultural patrimony in the University’s collections.

No one at the University is authorized to acquire for the University or accept on the University’s behalf any Native American and Native Hawaiian human remains, funerary objects, sacred objects, or objects of cultural patrimony without the prior written approval of the Provost or his or her authorized designee.  This includes any acquisition of such items by donation, loan or gift, as well as any acquisition of such items in connection with any teaching, research or other University-related activities.

Procedures:

The Provost’s office will develop procedures to this policy that outline the manner in which the University follows the requirements of NAGPRA with respect to Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony in the University’s collections.

Click here to view procedures for the Native American Graves Protection and Repatriation Act Policy.

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 other applicable University Policies.

Related Information:

For any questions regarding NAGPRA, please contact the University’s NAGPRA Coordinator: Jacqueline Veninger, 860-486-6953, jacqueline.veninger@uconn.edu.

For information and resources on NAGPRA including links to the most current versions of the law and regulations visit NPS National NAGPRA website: www.nps.gov/nagpra.

Policy History:

Adopted 04/24/2019 [Approved by the President’s Cabinet]

Communication with External Media, Policy on

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Title: Policy on Communication with External Media
Policy Owner: University Communications
Applies to: Faculty, Staff, and Student Employees
Campus Applicability: All campuses, including UConn Health
Effective Date: May 5, 2017
For More Information, Contact Tysen Kendig, Vice President for Communications
Contact Information: Phone: (860) 486-0871
Official Website: http://communications.uconn.edu/

REASON FOR POLICY

The University of Connecticut (“the University” or “UConn”) needs to be able to communicate accurately, effectively and consistently with a variety of diverse audiences including the media. University Communications is the primary and official liaison to the news media. It 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. University Communications is responsible for coordinating official University comment on all matters regarding the institution. This includes both proactive interaction and responses to requests. University Communications is responsible for disseminating and pitching news stories, responding to media inquiries, arranging interviews and visual productions, and handling requests for distribution of information on behalf of the University’s main campus in Storrs, UConn Health and all campus locations and programs.

The purpose of this policy is to gather the University’s existing policies regarding employee communication with external media into one accessible statement while reaffirming the University’s continuing commitment to the principles of academic freedom.  It incorporates policies on three distinct but related situations:

  1. Requests for Official University Position or Response
  2. Requests to Faculty Regarding Subject Matter Expertise
  3. Personal Speech

APPLIES TO

This policy applies to all University employees including administration, faculty, staff and student employees. employees at all campuses including the University’s main campus in Storrs, UConn Health, the regional campuses, and the School of Law. It applies to all employees in all programs wherever located. The policy applies to employees when they are acting in their capacity as employees of the University, including when they are asked questions.

POLICY STATEMENT

  1. Requests for Official University Position or Response

All inquiries seeking an official University response or a statement on behalf of the University should be directed to the University spokesperson within University Communications. All inquiries seeking an official response or statement specific to UConn Health and its clinical and academic areas should be directed to the UConn Health Information Officer.

Authorization to speak on behalf of the University may only be given by the President or the Vice President for Communications. No faculty or staff member may make official statements on behalf of the University without consultation with, and express authorization from, the President or University Communications.

University Communications will coordinate the University response with appropriate members of the University and UConn Health communities.

Any employee who has not been authorized by the President or University Communications to speak to the media in the context of his or her role as a University employee must direct inquiries from the media about the official University comment on all matters regarding the institution to the University spokesperson.

No employee is authorized to speak “off the record” on behalf of the University to media on any matter pertaining to the University.

University employees must adhere to relevant UConn policies as well as all federal, state and local laws and policies regarding the release of information about activities of the University, or its employees, students, volunteers, patients or research subjects, including those that apply to privacy and patient confidentiality such as HIPAA and FERPA.

  1. Requests to Faculty and Staff Regarding Subject Matter Expertise

UConn is proud of its faculty and staff, and their expertise and scholarship in a vast array of subjects and disciplines. Many senior administrators and staff also have expertise. Individual faculty, administrators and staff experts are encouraged to provide subject-specific commentary based on their scholarship in their academic concentration or their expertise in their professional field. This includes athletics coaches and staff on matters related to university athletic contests and team- or program-related matters.

When offices and/or individuals are contacted for their scholarly or professional expertise, they are encouraged and expected to notify University Communications that a media representative has made contact. University Communications facilitates accurate, ethical and timely news coverage of significant programs and the achievements of faculty, administrators, staff, students and alumni. University Communications is available at all times to consult with administrators, faculty and staff about the most effective ways to work with the media.

Any questions that fall outside of a faculty member’s academic interest or expertise should involve consultation with the University spokesperson, who can be a resource in these instances. Questions also may be referred to the University spokesperson for direct handling. Inquiries seeking an official University comment must be directed to the University spokesperson.

If a faculty or staff member is unsure of whether a question or request for comment from the media concerns the faculty or staff member’s area of expertise or seeks an official University position, University Communications must be consulted.

  1. Personal Speech

Nothing in this policy is intended to restrict the freedom of faculty and staff members to engage in their scholarly activities or their personal involvement in community activities. Nothing in this policy is intended to affect individual employees’ rights to express personal opinions on University or non-University actions and policies. Nothing in this policy is intended to restrict faculty or staff members from commenting on matters of public concern implicating an employer’s official dishonesty, deliberately unconstitutional action, other serious wrongdoing or threats to health and safety. When speaking or writing as a citizen, an employee should be accurate, should exercise appropriate restraint, should show respect for the opinions of others and should make every effort to indicate that he/she does not speak for the institution.

The University reaffirms its continuing commitment to the principles of academic freedom and its protections as set forth in Article XIV of the Laws and By-Laws of the University of Connecticut and the right to freedom of speech protected by the United States and Connecticut Constitutions.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, Office of Student Financial Aid Services – Student Employment Guide, applicable collective bargaining agreements, and any other applicable University policies and procedures.

 

Policy created:   [5/05/2017] (Approved by President’s Cabinet)

Vendor Code of Conduct

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Title: Vendor Code of Conduct
Policy Owner: President’s Committee on Corporate Social Responsibility
Applies to: Others
Campus Applicability:  Storrs, and Regional Campuses
Effective Date: January 9, 2013
For More Information, Contact Leslie Langworthy
Contact Information: (860) 486-5898
Official Website: http://www.csr.uconn.edu/

The University of Connecticut (“UConn”) has a longstanding commitment to the protection and advancement of socially responsible practices that reflect respect for fundamental human rights and the dignity of all people. UConn strives to promote basic human rights and appropriate labor standards for all people throughout its supply chain. Promoting these values in concrete practice is the central charge of the President’s Committee on Corporate Social Responsibility (http://csr.uconn.edu/).

UConn is also committed to  building a safe, healthy and sustainable environment through the conservation of natural resources, increasing its use of environmentally responsible products, materials and services (including renewable resources), and preventing pollution and minimizing waste through reduction, reuse and recycling. UConn is proactive about purchasing products that have these environmental attributes or meet recognized environmental standards, when practicable, and buying from entities committed to the support of campus sustainability goals.  The University seeks to partner and contract with vendors that demonstrate a similar commitment to these values. Selected vendors may be required to provide a comprehensive summary report of their corporate social and environmental practices.

Principal Expectations

The principal expectations set forth below reflect the minimal standards UConn’s vendors are required to meet.

Nondiscrimination. It is expected that vendors will not discriminate in hiring, employment, salary, benefits, advancement, discipline, termination or retirement on the basis of race, color, religion, gender, nationality, ethnicity, alienage, age, disability or marital status, and will comply with all federal nondiscrimination laws and state nondiscrimination laws[1], including Chapter 814c of the Connecticut General Statutes (Human Rights and Opportunities), as applicable, and further will provide equal employment opportunity irrespective of such characteristics, including complying, if applicable, with Federal Executive Order 1124b, and the Rehabilitation Act of 1973.

Freedom of Association and Collective Bargaining. It is expected that vendors will respect their employees’ rights of free association and collective bargaining, including, if applicable, complying with the National Labor Relations Act, and, if applicable, Chapters 561 and 562 of the Connecticut General Statutes (Labor Relations Act, Labor Disputes) and Chapters 67 and 68 of the Connecticut General Statutes (State Personnel Act, Collective Bargaining for State Employees).

Labor Standard Regarding Wages, Hours, Leaves and Child Labor. It is expected that vendors will respect their employees’ rights regarding minimum and prevailing wages, payment of wages, maximum hours and overtime, legally mandated family, child birth and medical leaves, and return to work thereafter, and limitations on child labor, including, if applicable, the rights set forth in the Federal Fair Labor Standards Act, the Federal Family and Medical Leave Act, the Federal Davis-Bacon Act and Chapters 557 and 558 of the Connecticut General Statutes (Employment Regulation, Wages).

Health and Safety. It is expected that vendors will provide safe and healthful working and training environments in order to prevent accidents and injury to health, including reproductive health, arising out of or related to or occurring during the course of the work vendors perform or resulting from the operation of vendors’ facilities. Accordingly, it is expected that vendors and their subcontractors will perform work pursuant to UConn contracts in compliance with, as applicable, the Federal Occupational Safety and Health Act and Chapter 571 of the Connecticut General Statutes (Occupational Safety and Health Act).

Forced Labor. It is expected that vendors will not use or purchase supplies or materials that are produced using any illegal form of forced labor.

Harassment or Abuse. It is expected that vendors will treat all employees with dignity and respect, and that no employee will be subjected to any physical, sexual, psychological or verbal abuse or harassment.  It is further expected that vendors will not use or tolerate the use of any form of corporal punishment.

Environmental Compliance. It is expected that vendors will comply with all applicable federal and state environmental laws and Executive Orders, including but not limited to Titles 22a and 25 of the Connecticut General Statutes (Environmental Protection and Water Resources protection) and Executive Order 14 (concerning safe cleaning products and services). UConn expects vendors will employ environmentally responsible practices in the provision of their products and services.

Preferential Standards

The preferential standards set forth below reflect UConn’s core values. UConn will seek to uphold these values by considering them as relevant factors in selecting vendors.

Living Wages. UConn recognizes and affirms that reasonable living wages are vital to ensuring that the essential needs of employees and their families can be met, and that such needs include basic food, shelter, clothing, health care, education and transportation.  UConn seeks to do business with vendors that provide living wages so as to meet these basic needs, and further recognizes that compensation may need to be periodically adjusted to ensure maintenance of such living wages.  Vendors are encouraged to demonstrate that they pay such living wages.

International Human Rights. For UConn, respect for human rights is a core value.  UConn seeks to do business with vendors who do not contribute to or benefit from systemic violations of recognized international human rights and labor standards, as exemplified by the Universal Declaration of Human Rights.

Foreign Law. UConn encourages vendors and vendors’ suppliers operating under foreign law to comply with those foreign laws that address the subject matters of this code, provided such foreign laws are consistent with this code. Vendors and their suppliers operating under foreign law are similarly encouraged to comply with the provisions of this code to the extent they can do so without violating the foreign law(s) they operate under.

Environmental Sustainability. UConn will prefer products and services that conserve resources, save energy and use safer chemicals, such as recycled, recyclable, reusable, energy efficient, carbon-neutral, organic, biodegradable or plant-based, in addition to products that are durable and easily reparable, and that meet relevant certification standards above and beyond those required by law. While UConn is not legally bound to comply with Connecticut General Statutes 4a-67a through 4a-67h concerning environmental sustainability standards in purchasing, it will nevertheless consider vendors’ ability to meet those standards in rendering its purchasing decisions. Vendors are encouraged to demonstrate their commitment to environmental sustainability.

Compliance Procedures

Anyone who believes a vendor doing business with UConn has not complied or is not complying with this code may contact the University’s REPORTLINE at 1-888-685-2637 or https://uconncares.alertline.com/gcs/welcome.  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 Office of Audit, Compliance and Ethics, who will evaluate the concerns raised and, if necessary, refer the matter to the most appropriate University office for review.

The Office of University Compliance has the authority to investigate such matters, and if warranted, recommend remedial action to the UConn administration.

[1] Wherever this code refers to compliance with federal or state laws, that term includes compliance with any regulations duly promulgated pursuant to such laws.

Policy Created: January 7, 2013 (Approved by the President’s Cabinet)

Revised: July 14, 2015

Non-Retaliation Policy

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Title: Non-Retaliation Policy
Policy Owner: Office of the President
Applies to: Faculty, Staff, Students, Contractors and Affiliated Persons
Campus Applicability:  All Campuses
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 Building263 Farmington AvenueFarmington, 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
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) 679-3563Fax: (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 Building263 Farmington Avenue Farmington, CT 06030 – 4035
Telephone: 860-679-8067Website: 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) 486-4800Website: https://publicsafety.uconn.edu/police/		 University of Connecticut Police Department
263 Farmington AvenueFarmington, CT 06030 – 3925
Telephone:  860-486-4800Website: 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/cpfu_wp/
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://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)