[Faculty Handbook Category #3]
Introduction
St. Olaf College (the College) has built and maintained its reputation for integrity and honesty by following the highest standards in its practices. These standards go beyond the requirements of the law. All of us contribute to this reputation every day by the way we conduct ourselves. This Code of Conduct applies to all employees of the College. As appropriate standards of conduct cannot always be defined by strict rules, this Code of Conduct cannot address every situation that you may confront in the day-to-day conduct of your many activities at the College. This Code can, however, give you guidance and direct you to resources to help you make the right decisions.
Human Resources Department and Campus Conduct Hotline
The Human Resources Department is here to assist you in adhering to your ethical and legal responsibilities, and to contact the appropriate individuals that are responsible for investigating allegations of conduct that conflicts with our responsibilities, as set forth in this Code of Conduct or otherwise, or violates applicable law. You are expected to promptly report any conduct that you believe violates the ethical and legal responsibilities of a St. Olaf College employee. Such reports may be made on a confidential and/or anonymous basis. You may report such conduct to your supervisor or to a member of the Human Resources Department. Such persons will strive to maintain the confidentiality of any report to the maximum extent consistent with fair and rigorous review of the conduct. Alternatively, if you wish to remain anonymous, you may report such conduct by calling the Campus Conduct Hotline at 1-866-943-5787. Retaliation against anyone who reports suspected conduct that is believed to violate the ethical or legal responsibilities of a St. Olaf College employee is strictly prohibited. You will not suffer any penalty for reporting in good faith any suspected violation.
General Policy
It is the College’s policy to observe and comply with all laws, rules and regulations applicable to the conduct of its business in all countries in which it operates. Involvement in, or the use of the College assets for, any unlawful purpose is strictly forbidden. As the College’s employees, we are required not only to avoid any unlawful activity, but also any activity that would reflect unfavorably on the College. The College is committed to the highest standards of business and personal ethics for itself and its employees because acting in accordance with such standards is morally and legally right. The College’s success depends on a multitude of factors, which include its reputation for integrity and on the trust of the public, the college community, donors, suppliers, students and government and regulatory authorities.
Ask First
As noted above, this Code of Conduct cannot address every situation that you may confront in the day-to-day conduct of your many activities at the College. This is especially true because our work, as guided by the Mission Statement of the College, is complex and the right thing to do may not always be clear. The College does not expect you to always determine the right answer to complex questions of law or ethics on your own. Instead, if you encounter a situation where the application of the guidelines contained in this Code is not clear or seems inappropriate, you should consult with your supervisor or a member of the Human Resources Department. In short, if you are uncertain about any situation, ask for guidance.
Discipline
Failure to comply with this Code of Conduct may result in disciplinary actions consistent with the College’s employment policies or agreements. Such disciplinary actions up to and including warnings, suspensions (with or without pay), termination of employment or other actions as may be appropriate under the circumstances may be taken, for example, for the following:
- Authorizing or participating in activities that violate this Code of Conduct.
- Deliberately failing to report conduct that you believe violates this Code of Conduct or withholding relevant and material information concerning a suspected violation.
- Retaliating directly or indirectly—or encouraging others to do so—against an employee who reports a suspected violation of this Code of Conduct.
- This list is not intended to be exhaustive and other incidents and behaviors can also result in disciplinary action, including termination.
Conflicts of Interest
In order to thrive, the College must have the loyalty of each of its employees. As an employee, you must be free of conflicting interests in the performance of your duties for the College because conflicts of interest might influence your judgment and cause you to make a decision that is not in the best interest of the College. As a general guideline, you must avoid any situation where your personal interests could conflict with, or create the appearance of conflicting with, the interests of the College.
For more specific guidelines regarding conflicts of interest, please see the College’s Conflict of Financial Interest Policy. If you have any doubt or concern that a situation may create a conflict of interest, or the appearance of a conflict of interest, you should discuss your concern with your supervisor, the Treasurer, or a member of the Human Resources Department.
Fraud
The College will not tolerate fraudulent business practices. All employees of the College play an important role in detecting, reporting and preventing fraud. If you detect, or are suspicious of, fraudulent activities, you are required to immediately report your concern to your supervisor, the Treasurer, or to a member of the Human Resources Department, or by calling the Campus Conduct Hotline.
Use of Assets
The College’s assets are to be used solely for the benefit of the College. You are responsible for assuring that any assets of the College that you are responsible for are used only for valid College business purposes. You may not use the College’s assets to provide personal gain for yourself or others. You may not loan, borrow, donate, sell or dispose of any of the College’s assets unless you are specifically authorized to do so.
Confidential Information
It is very important that you comply with laws governing disclosure of student and other protected information and appropriately safeguard the College’s confidential information and refuse any improper use or disclosure of the confidential information. In terms of the College’s confidential information, our basic guidelines are as follows:
- You should only discuss confidential information with others within the College on a need-to-know basis. If you provide or discuss confidential information with another employee within the College, you should ensure that such person is aware of its confidential nature. You should not share confidential information with individuals who are not employees of the College unless they are under contract with the College and bound by a non-disclosure agreement.
- All employees with access to student information are expected to be conversant with the requirements of the Family Education Rights and Privacy Act (FERPA). See: https://wp.stolaf.edu/registrar/ferpa/
- You must guard against accidental disclosure of confidential information. If you have access to the College’s computer systems, including portable devices such as laptops, tablets, or smartphones, you are responsible for taking precautions necessary to prohibit unauthorized access to the system, including safeguarding your passwords or other means of entry.
Corporate Records
The College’s corporate records, including, but not limited to, business records, accounting records, time sheets, student records, expense reports, bills, payroll, service records, reports to government agencies and other essential records, are to be prepared and maintained with accuracy, honesty and in strict compliance with applicable laws or procedures. These records are the basis for managing the College’s business and for fulfilling its obligations to its employees, donors, suppliers, students and regulatory authorities.
If you determine that there has been an omission from, or inaccuracy in, the College’s corporate records, you should immediately report such omission or inaccuracy to your supervisor or to a member of the Human Resources Department, or by calling the Campus Conduct Hotline
Compliance with Government Investigations
It is the College’s policy to cooperate with governmental agencies and authorities in their proper performance of inquiries or investigations. If you receive a request from a governmental entity, either oral or written, for information that you do not ordinarily provide to the government in the regular course of your job, such request should be forwarded to your supervisor.
If you are asked to participate in responding to a governmental request, you should provide truthful and accurate information. You should never destroy documents in response to an investigation. For more specific guidelines regarding the College document retention policy, please see the College’s “Record Retention/Destruction Policy” on the College’s website.
Global Practices
It is the goal of the College to be a good corporate citizen in each country in which it operates. The College can achieve this goal only if its employees obey all of the laws and regulations of, and respect the lawful customs of, all countries in which the College operates. If you are unsure about appropriate business behavior in another country, be sure to speak with your supervisor or a member of the Human Resources Department.
Dealing With Donors, Suppliers and Students
The College’s viability depends on the quality and value of its services and the respect and confidence that it instills in its donors, suppliers and students. It is your responsibility to treat all persons with whom you conduct business honestly, fairly and objectively.
Bribery and Kickbacks
The College will not pay bribes or kickbacks to any person for any purpose, including for the purpose of obtaining or rewarding favorable treatment in a business transaction or for the purpose of influencing the judgment or actions of another. Such practices are not only unethical, but in many cases both in the United States and in other countries, are illegal.
Gifts, Entertainment and Other Items of Value
Occasionally, people or companies with whom the College conducts business may offer gifts, entertainment or other items of value in appreciation for their business relationship with the College. While the College recognizes that it is advantageous to develop and maintain good business relationships, we also require that our employees guard against engaging in any activity, or accepting gifts, entertainment or other items of value, that may encourage, or give the perception of encouraging, inappropriate favoritism toward any person or company.
It is never appropriate for you to solicit or accept a gift of money or for you to solicit a nonmonetary gift, entertainment or other item of value for your own personal benefit from any person or company. You may accept unsolicited, nonmonetary gifts, entertainment and other items of value from a person or company that does, or is seeking to do, business with the College if such gift, entertainment or item is of nominal value (generally less than $50) and you report the same to your supervisor. Gifts, entertainment and other items of more than nominal value may be accepted only if approved in advance by your supervisor. If you have any doubt or concern that the receipt of any gift, entertainment or other item of value may be inappropriate, or cause the appearance of impropriety, you should discuss the same with your supervisor or a member of the Human Resources Department.
Business Defamation
You may not make false or misleading remarks about individuals or organizations or their products and services. In particular, you may not make false or misleading remarks about the College’s competitors or their products, services or employees. All comparisons between the College services and those of a competitor must be accurate and factual. You must accurately represent the College services in all marketing, advertising and sales contacts.
Contacts with News Media
The College strives to maintain a positive working relationship with the news media. The College is as open and candid with the media as possible, but there are times when we cannot or will not provide requested information. Confidential information that cannot be released is addressed above. It is the College’s policy to cooperate with the media in a professional and timely manner by providing appropriate information. In order to do this, all calls or inquiries from the media must be forwarded to the Communications Department.
Harassment
The College prohibits and does not tolerate unlawful harassment of employees, contractors, vendors, students or visitors. The College also prohibits consensual relationships between a faculty or staff member and any student enrolled at the College. For more specific guidelines, please see the sections of your Employee Handbook entitled “Harassment Policy,” “Sexual Harassment Policy,” and “Consensual Relations.” If you believe you have been the victim of harassment in violation of this policy, you should immediately contact the Director of Human Resources or the Campus Conduct Hotline.
Nondiscrimination and Equal Opportunity
The College is strong because of the strength of its employees. For that reason, the College seeks to provide a work environment where all employees have an equal opportunity to reach their full potential and contribute to the College’s success. You must not discriminate against any employee or applicant for employment because of race, color, creed, religion, sex, sexual orientation, age, national origin, disability, marital status, status with regard to public assistance or any other classification protected by law. Further, you must not refuse to conduct business with any person on the grounds of that person’s race, color, creed, religion, sex, sexual orientation, age, national origin, disability, marital status, status with regard to public assistance or any other status protected by law. For more information about the College’s nondiscrimination policy, see the policies entitled “Equal Opportunity Employer” and “Harassment Policy” in the College Faculty and Staff Handbooks. If you believe you have been discriminated against in violation of this policy, you should contact a member of the College’s Human Resources Department or the Campus Conduct Hotline.
Safety, Violence and Health
The College is committed to providing a safe and healthy workplace for its employees and visitors. It is the College’s policy to comply with all applicable health and safety laws and regulations and to insist that work be done in a healthy, safe and responsible manner.
In order to create an environment free from threats, violence and intimidation, the College is committed to a policy of zero tolerance for violence. You are not permitted to have firearms or other weapons on the College property at any time. Individuals who possess a valid permit to carry a concealed weapon may, however, keep the weapon locked in the trunk or glove compartment of their vehicle in the parking lot. If you observe weapons to be present on the College property, you should dial 911 if it is an emergency situation, or otherwise immediately contact the Public Safety Office, your supervisor or Human Resources.
Environment
The College is committed to maintaining the environment and minimizing the impact of its business operations on the land, air and water. This commitment can be met only through your awareness and cooperation in conservation and recycling efforts.
In the United States, federal, state and local regulatory agencies exist to monitor and enforce compliance with laws and regulations affecting environmental protection. It is the College’s policy to comply with both the letter and the spirit of the laws and regulations imposed by these agencies and to exhibit a cooperative attitude with inspection and enforcement personnel from the agencies. In keeping with this spirit, you should report to your supervisor or to a member of the Human Resources Department any conditions that you perceive to be hazardous to the environment.
Drug-Free, Alcohol-Free and Smoke-Free Environment
The College is committed to providing a safe, efficient and productive workplace, and, therefore, offers its employees a drug-free, alcohol-free and smoke-free working environment. Employees are to comply with all State and Federal laws related to drugs and alcohol. Please refer to the Faculty and Staff Employee Handbook section: “Alcohol and Drug Use”. Individuals who operate College vehicles, machinery or equipment must exercise caution when using certain prescription medications. In addition, use of or involvement with illegal drugs outside of your employment with the College will not be tolerated because it can negatively affect your ability to do your job, and the College’s reputation and ability to conduct business. The only exception to this policy permits alcoholic beverages to be served at some official social or business functions sponsored by the College.
The College expects that you will use good judgment in work-related social settings, particularly when participating in events where alcoholic beverages are served.
The College’s buildings are smoke-free environments. As such, you must not smoke anywhere inside these buildings. Additionally, employee meetings conducted off of the College’s property are, when practicable, smoke- free.
Community and Political Activities
The College is committed to upholding and contributing to the political, legal and governmental processes of the local, state and federal governments of the United States and other countries in which the College operates. The College recognizes that participation by citizens in civic and political activities is necessary for communities and the democratic system to properly function. The College encourages you, as an individual citizen, to exercise your right to vote, to participate actively in community activities and the political process, to be informed on public issues, to be informed on positions and qualifications of public officials and candidates for public office, and to support the issues, candidates and parties of your choice.
When you are involved in any community and political activities, you must at all times make clear that your views and actions are your own and not those of the College. You must not use the College’s name, either directly or indirectly, to endorse any public issue, political candidate or political party, unless previously approved by the President or Provost. You may not make community donations or political contributions on behalf of the College, unless previously approved by the President or Provost.
If you have any questions about what is or is not proper with respect to community or political activities, you should consult with your supervisor or a member of the Human Resources Department.
Conclusion
As a St. Olaf College employee, you are expected to understand and comply with this Code of Conduct. If there are any concerns as to how to deal with ethical questions or questions regarding this Code, you should contact your supervisor or a member of the Human Resources Department. If you believe that any of policies in this Code of Conduct has been violated, you should contact your supervisor, a member of the Human Resources Department, or the Campus Conduct Hotline.