All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University.
The purpose of this Policy is to establish a standard of conduct to protect the financial well-being, reputation, and legal obligations of Thomas More University, as well as establish a method to protect the University community from questionable circumstances that might arise.
Institutional Data: is any information, including Directory Information, Personally Identifiable Information, and Student and Employee Financial Information that can be linked to any individual, including but not limited to, students, faculty, staff, patients, or contractors. Institutional Data and all applications storing and transmitting such data, regardless of the media on which they reside, are valuable assets, which the University has an obligation to manage, secure, and protect.
Directory Information: means information contained in an education record of a student that would not generally be considered harmful or an invasion of privacy if disclosed. The University designates the following categories of student information as public, or directory information: a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, the most recent educational agency or institution attended, electronic mail addresses and photographs. It also states that directory information does not include a student’s social security number or student identification number. “Directory information” however, does include student identification numbers or user identification when such identifiers cannot be used to gain access to education records unless used in conjunction with other factors authenticating the user’s identity.
Employee Financial Information—that information the University has obtained from an employee in the process of offering a benefit or service. Offering a benefit or service includes all University sponsored benefit plans and University financial services such as flexible spending accounts, and personal payroll services. Examples of employee financial information include bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format.
Personally Identifiable Information (“PII”): PII is any information about an individual maintained by an agency, including (1) any information that can be used to distinguish or trace an individual‘s identity that is not been designated as directory information, such as social security number, place of birth, mother’s maiden name, or biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information relating to an identified or identifiable person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.
Student Financial Information—that information the University has obtained from a student in the process of offering a financial product or service, or such information provided to the university by another financial institution. Offering a financial product or service includes offering student loans to students, receiving income tax information from a student’s parent when offering a financial aid package, and other miscellaneous financial services as defined in 12 CFR § 225.28. Examples of student financial information include bank and credit card account numbers, income and credit histories and social security numbers, in both paper and electronic format.
The successful business operation and reputation of Thomas More University is built upon the principles of fair dealing and ethical conduct of the University’s employees. The University’s reputation for integrity and excellence requires careful observance of the spirit and the letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity.
The continued success of the University is dependent upon building and maintaining the trust of all its business relations, including its customers and vendors. Thomas More University is dedicated to preserving that trust. Employees owe a duty to the University and its clients to act in a way that will merit the continued trust and confidence of the public.
Thomas More University complies with all applicable laws and regulations and expects its officers and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct in their dealings with persons both inside and outside the University. Accordingly, the University has promulgated Standards of Ethical Conduct, which sets forth the general standards to which every University officer and employee is expected to adhere. These standards, which are set forth in the Procedures section of this Policy, have been derived from federal, state, and local laws and regulations, University policies and procedures, contractual and grant obligations, and generally accepted principles of ethical conduct. Compliance with the Standards of Ethical Conduct is the responsibility of every Thomas More employee.
Anti-Bribery and Corruption Policy
Acceptable Use Policy
Confidential Information Policy
Conflict of Interest Policy
Consensual Relations Policy
Harassment in the Workplace Policy
Record Retention Policy
Sexual Misconduct Policy
The Standards of Ethical Conduct applies to all University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University.
A. Adherence to Standards of Ethical Conduct
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to conduct themselves at all times ethically, honestly, and with integrity in all dealings in accordance with the highest professional and community ethical standards.
In addition, those engaged in research are expected to conduct their research with integrity and intellectual honesty at all times and with appropriate regard for human subjects. To protect the rights of human subjects, all research involving human subjects is to be reviewed by the University’s Institutional Review Board (IRB). All research involving living animal subjects is to be reviewed by the University’s Institutional Animal Care and Use Committee (IACUC).
Members of the University community engaged in research are not to: fabricate data or results; change or knowingly omit data or results to misrepresent results in the research record; or intentionally misappropriate the ideas, writings, research, or findings of others. They are also expected to demonstrate accountability for sponsors’ funds and to comply with specific terms and conditions of contracts and grants.
B. Compliance with Applicable Laws & Regulations
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to become familiar with the laws and regulations applicable to his or her position or status with the University, and must not act in any way to intentionally breach such laws and regulations, nor should they ask others to do so. Questions and concerns about the legality or propriety of any action or failure to take action by or on behalf of the University should be referred to the employee’s immediate supervisor or the Director of Human Resources.
C. Compliance with Applicable University Policies and Procedures
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are guided by the mission and values of Thomas More University and are bound by the policies, procedures, and practices set forth in the University’s policy documents (see e.g., Employee Policies, Faculty Policy Manual, Catalogue, and other policy-related documents).
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to seek clarification on a Policy or other University directive he or she finds to be unclear, outdated or at odds with the University’s mission or values. It is not acceptable to ignore or disobey policies if one is not in agreement with them, or to avoid compliance by deliberately seeking loopholes.
In some cases, University officers and employees are also governed by ethical codes or standards of their professions or disciplines. It is expected that those officers and employees will comply with applicable professional standards in addition to laws and regulations.
D. Conflicts of Interest or Commitment
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University have a duty to avoid conflicts between his or her personal interests and official responsibilities and to comply with University policies for reporting and reviewing actual and potential conflicts of interest and conflicts of commitment. Additionally, such individuals may not utilize their position with the University for their personal benefit. Areas of potential conflict include the use of Institutional Data, University purchases not subject to competitive bids, the acceptance of gifts and, under certain conditions, outside employment. Members of the community are also expected to consider and avoid, not only an actual conflict but also, the appearance of a conflict of interest. See the University’s Conflict of Interest Policy. In all matters, University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to take appropriate steps, including consultation if issues are unclear, to avoid both conflicts of interest and the appearance of such conflicts.
E. Respect for the Rights and Dignity of Others
Thomas More University is committed to a work, academic, and residential environment in which all individuals are treated with respect and dignity. Each individual has the right to work, study, and live in a professional, academic, and residential atmosphere that promotes equal employment and educational opportunities and prohibits discriminatory practices, including harassment. The University prohibits discrimination and harassment and provides equal opportunities for all community members and applicants regardless of race, color, religion or creed, disability of a qualified individual, veteran status, military service, age, national or ethnic origin(including ancestry), citizenship, genetic information, pregnancy, sex, sexual preference (or orientation), or any other applicable legally protected status. See the Harassment in the Workplace and Sexual Misconduct policies. Further, romantic or sexual relationships between faculty responsible for academic supervision, evaluation or instruction and their students are prohibited. See the Consensual Relations Policy.
F. Confidential Information
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University who have access to the University’s Institutional Data are expected to be familiar and to comply with applicable laws (e.g. FERPA), University policies, directives and agreements pertaining to access, use, protection and disclosure of such information. Computer security and privacy are also subject to law and University policy. Any request for such information should be referred to the supervisor, and the supervisor in turn should refer requests of this nature to the appropriate person.
G. Use of University Resources
University resources may only be used for activities on behalf of the University. They may not be used for private gain or personal purposes except in limited circumstances permitted by existing policy where incidental personal use does not conflict with and is reasonable in relation to University duties (e.g., telephones). All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to treat University property with care and to adhere to laws, policies and procedures for the acquisition, use, maintenance, record keeping and disposal of University property.
H. Compliance with Contractual Terms and Grant Terms and Conditions
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to maintain access to and to comply strictly with the terms and conditions of each University grant and contract on which he or she is working. All questions or concerns about whether a particular term or condition violates the law or whether the grantor or contractor has breached its obligations to the University should be referred promptly to the Chief Financial Officer.
I. Maintenance and Preservation of Records
All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University are expected to create and maintain records and documentation which fully conform to all applicable laws and professional, and ethical standards. Every member of the college who is involved, directly or indirectly, in the preparation or submission of a bill to any governmental or private payor is expected to use his or her best efforts to ensure the bill addresses only those services rendered and products delivered and in the correct amount, supported by appropriate documentation.
In general, the use of good judgment, based on high ethical principles, will guide University employees with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with the employee’s immediate supervisor or the Director of Human Resources. In addition, the reporting procedures set forth in the University’s Whistleblower Policy may be utilized.
Those who report violations in good faith and in an appropriate manner, whether or not further investigation substantiates the claim, will be free from retaliation in any form. The identity of the reporter will be protected, within legal limits, and those who retaliate against them will be disciplined. All reported violations will be investigated promptly.
Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action up to and including termination of employment. In addition, conduct that violates this Policy may result in civil or criminal charges and penalties against the violator.
This is a new policy, replacing language in the Staff Manual (May 2014).
There are no appendices to this Policy.
Laura Custer, Director of Human Resources
Rob Munson, Chief Financial Officer
Dr. Kathleen Jagger, Acting President