Code of Conduct

A statement about expectations of employees regarding ethical behavior, fraud, dishonesty and misconduct.

Eastern Mennonite University’s reputation is an important asset and each employee individually shares responsibility for maintaining that reputation. This code of conduct is intended to guide the personal business ethics of all of us. All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing the university’s worldwide operations.

Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should consult with the vice president for finance for possible referral to legal counsel.

Guiding Principles:

Be a role model for ethical conduct
Protect and enhance the university’s assets and reputation
Understand and comply with the laws, regulations and university policies that apply to your job
Provide a work environment free from intimidation and harassment
Do not accept gifts or gratuities offered to you individually from vendors or suppliers
Do not engage in activities individually that create an actual or perceived conflict of interest situation that results in personal enrichment
Ensure that financial records are accurate and complete
Comply with the university’s travel and expense reimbursement policy
Retain key corporate documents, including those related to lawsuits and investigations
Protect and properly use university property
Do not pressure employees, students or anyone else in a business relationship with the university to contribute to or support political candidates or causes
Safeguard the privacy, confidentiality and security of customer data and confidential university information
Protect university trademarks, copyrights and patents
Do not agree with competitors to limit competition
Make only factual and truthful statements about the university’s programs; do not disparage competitor’s programs
Guard against the use of university services for the purposes of money laundering or for the financing of terrorism or other criminal activity by only dealing with reputable persons and business partners
Report any known or suspected violations so that remedial action can be taken

General Employee Conduct

The university expects its employees to conduct themselves in a businesslike manner. Employees must not engage in sexual harassment, or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer. See also Community Lifestyle Commitment

Conflicts of Interest

The university expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the university. Employees must not use their position or the knowledge gained as a result of their position for private or personal advantage or to secure any item or benefit that would not ordinarily accrue to them in the performance of their official duties. Nor shall they accept any compensation from any other agency or individual for work performed in the course of their salaried employment by the University. Employees engaged in consulting or other outside employment must avoid the use of information or procedures that might involve a conflict of interest with assigned University responsibilities. This policy applies to sponsored research programs with contractual restrictions such as patents and copyrights, and to any outside employment that interferes with satisfactory job performance in a University position.

Regardless of the circumstances, if employees sense that a course of action they have pursued, are presently pursuing, or are contemplating pursuing may involve a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

Supplemental Policy: Contracts & Awards

No employee, officer, or agent shall participate in the selection, award or administration of a contract supported by federal, state or local municipality funds if a real or apparent conflict of interest would be involved. A conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm selected for a contract award. The officers, employees, and agents of the recipient shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or parties to sub-agreements. The only exceptions to the above standards are situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value.

The University reserves the right to require an employee to file a disclosure statement of their personal financial interests where required by specific federal awards or where desired by the University in order to determine conflict of interest.

Violations of these standards shall be cause for disciplinary action by the University in accordance with policies set forth in the Employee Handbook.

Outside Activities, Employment, and Directorships

All employees share a serious responsibility for the university’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to the university and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside the university that would appear to create an excessive demand upon their time and attention. Employees must also avoid any conflict in the form of obligation, interest, or distraction that may interfere with the independent exercise of judgment in the university’s best interest.

Outside Employment and Consulting

External assignments considered by faculty, staff and administrators at EMU must be approved by the individual's supervisor. These would include outside teaching assignments, other employment, consulting and speaking engagements which would require a significant (define significant) time away from the job. When such assignments conflict with institutional responsibilities, the release time is to be negotiated by the individual with the administration. The principle is that persons not receive double remuneration for the same activity and that there be some monitoring of outside assignments which would potentially affect performance of primary responsibilities.

Relationships with Clients and Suppliers

Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with the university, or that provides goods and services, or both, to the university, if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of the university.

Kickbacks and Secret Commissions

Regarding the university’s business activities, employees may not receive payment or compensation of any kind, except as authorized under the university’s remuneration policies. In particular, the university strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Persons making business decisions regarding vendors and suppliers for the university should not accept gifts or gratuities offered to them personally that may influence or create the perception of influencing their choice of vendor or supplier. A breach under this rule may result in termination and prosecution to the fullest extent of the law.

University Funds and Other Assets

Employees who have access to university funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in the university’s instructional manuals or other explanatory materials, or both. The university imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud or dishonesty, they should immediately advise their supervisor or the vice president for finance so that the university can promptly investigate further.

When an employee’s position requires spending university funds or incurring any reimbursable personal expenses, that individual must use good judgment on the university’s behalf to ensure that good value is received for every expenditure.

Organization funds and all other assets of the university are for university purposes only and not for personal benefit. This includes the personal use of university equipment, except as authorized by university policy. See also Cash/Check Transmittal Form and Credit Card Transmittal Form. See also Business Travel Expense Policy.

University Records and Communications

Accurate and reliable records of many kinds are necessary to meet the university’s legal and financial obligations and to manage the affairs of the university. The university’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.

Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:

False expense, attendance, production, financial, or similar reports and statements.
False advertising, deceptive marketing practices, or other misleading representations.

Dealing With Outside People and Organizations

Employees must take care to separate their personal roles from their university positions when communicating on matters not involving university business. Employees must not use organization identification, stationary, supplies and equipment for personal or political matters.

When communicating publicly on matters that involve university business, employees must not presume to speak for the university on any topic, unless they are certain that the views they express are those of the university, and it is the university’s desire that such views be publicly disseminated.

When dealing with anyone outside the university, including public officials, employees must take care not to compromise the integrity or damage the reputation of either the university, or any outside individual, business, or government body.

Prompt Communications

In all matters relevant to customers, suppliers, government authorities, the public and others in the university, all employees must make every effort to achieve complete, accurate, and timely communications—responding promptly and courteously to all proper requests for information and to all complaints. See also Open Communication Policy.

Privacy and Confidentiality

When handling financial and personal information about customers or others with whom the university has dealings, observe the following principles:

Collect, use and retain only the personal information necessary for the university’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use personal information only for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.

Responsibilities, Reporting, Consequences

Employees who are or become aware of violations of this Code of Conduct or other instances of employee dishonesty, fraud or misconduct must report such violations to their supervisor, a vice president, or in cases involving a vice president, to the president of the university. Any reprisal against an employee or other reporting individual who, in good faith, reported an incident or violation is strictly forbidden.

Due to the important and sensitive nature of suspected violations, managers receiving reports should not perform investigative or other follow up steps on their own. Concerned managers without proper training represent one of the greatest threats to proper incident handling. All relevant matters, including suspected but unproven matters, should be referred immediately to persons with follow up responsibility. The President’s Office has primary responsibility for all investigations involving the university. The university is committed to the deterrence, detection and correction of misconduct and dishonesty. The discovery, reporting and documentation of such acts provides a sound foundation for the protection of innocent parties, the taking of disciplinary action against offenders up to and including dismissal where appropriate, the referral to law enforcement agencies when warranted by the facts, and the recovery of assets.

Adopted President’s Cabinet, June 9, 2004

Revised and approved by President’s Cabinet, June 8, 2011