Policy Number: C0.0
Policy Name: COMPLIANCE POLICY AND CODE OF ETHICAL CONDUCT
RIT provides educational and research opportunities for its students to prepare them for excellence and successful careers in a global society. As part of this educational and research mission, RIT has developed this policy to help guide students, faculty, staff, and trustees in their conduct. In particular, this policy references other applicable RIT policies and procedures, ethical and legal obligations, the responsibility to seek guidance when questionable conduct is witnessed, and the obligation to report potential violations of this policy and its incorporated code standards, free of any fear of retaliation.
This policy will be administered by the chief risk and compliance officer. Audit and monitoring activities conducted by the Institute Audit, Compliance & Advisement Office will be utilized to assist in compliance with this policy.
This policy will be effective on December 9, 2009 (“Effective Date”). It will apply to all divisions, departments, and academic units of RIT.
This policy and code applies to all members of the RIT community, including students, faculty, staff, and trustees. It governs all community members’ conduct while representing RIT, utilizing RIT's resources, being on RIT property, or while attending RIT functions. This policy and code incorporates the RIT Compliance Program and Procedures that seek to ensure ethical, legal, and regulatory compliance available at the Office of Legal Affairs website. This policy and code should be read with the other RIT polices available online at www.rit.edu/academicaffairs/manual, as well as the specific policies and procedures incorporated below that already address key obligations and compliance risk areas for members of the RIT community.
RIT expects adherence to the requirements of this policy and code and these identified RIT policies at all times. The mere absence of a specific policy does not relieve any individual in the RIT community of the responsibility to apply the highest ethical standards when reacting to a situation on behalf of, or at, RIT.
B. Standards of Ethical Conduct
All members of the RIT community should take effective measures to conduct themselves ethically, with integrity, and in compliance with applicable laws and regulations. These standards referenced below are designed to help codify key RIT expectations and to supplement RIT's Core Values into a Code of Ethical Conduct.
- Respect for Others
Every member of the RIT community deserves to be treated with respect and dignity. RIT prohibits discrimination and harassment and provides equal opportunities for all community members and applicants regardless of race, color, national origin, citizenship, ancestry, religion, marital status, age, sex, gender identity, sexual orientation, pregnancy, physical or mental disability, or any other status or condition. In your actions on behalf of RIT, all members of the RIT community should treat others with courtesy, civility, and dignity and not abuse the power or authority of their offices or roles.
- Individual Responsibility and Accountability
Each individual member of the RIT community is expected to behave ethically, honestly and with integrity in all interactions with others both inside and, when conducting RIT business, outside the RIT community. Members of the RIT community must exercise responsibility appropriate to their position and delegated authorities. Members must conduct university business in accordance with RIT's Core Values and the Standards of Ethical Conduct, exercising sound judgment and serving the best interests of RIT and the community. When roles, responsibilities, or reporting relationships are unclear, individuals should seek clarification from their supervisors, deans, division heads, or the compliance officer.
- Responsible Conduct of Teaching and Research
As part of its educational and research mission, RIT is devoted to the pursuit of knowledge and the respectful free exchange of ideas. RIT is committed to achieving the highest standards of teaching and research and to conducting these activities with integrity, objectivity, fairness, and in compliance with all applicable laws and regulations. Members of the RIT community pursuing scientific and other academic research are expected to take seriously this commitment. First, members of the RIT community must conduct their research with rigor, intellectual honesty, and be accountable for sponsors’ funds. Second, researchers must comply with specific grant and contract requirements as well as university policies and procedures regarding research. Finally, researchers must comply with all federal and state regulations involving research, including the protection and welfare of human and animal research subjects, and obtain appropriate approval and consents for studies involving such subjects.
- Avoidance of Individual Conflicts of Interest and Commitment
The university encourages interactions with external entities that are beneficial to the professional standing of employees, the reputation and mission of the university, or serve the community or profession at large. Such interactions may potentially create conflicts of interest or commitment. In either case, however, the university expects all members of the RIT community to avoid ethical, legal, financial, or other conflicts of interest or commitment, including even the appearance of a conflict, that might impede or compromise their responsibilities or the mission of RIT.
Most potential, real, or perceived conflicts of interest and commitment which occur during the course of everyday life within the RIT community can be managed through disclosure and transparency. Unreported or unresolved conflicts, on the other hand, can disrupt or even potentially threaten the integrity of the individual and scholarship, research, instruction, evaluation, or administration of the university. Thus, potential conflicts must be disclosed in accordance with the RIT Individual Conflict of Interest and Commitment (ICIC) Policy.
- Business and Financial Recordkeeping and Reporting
As an organization receiving private and public funds, it is critical that all those members of the RIT community responsible for accounting, financial recordkeeping, and/or financial reporting are accurate and thorough at all times. These members must record and report accurately revenue, expenditures, time, effort, etc., in accordance with RIT policies and procedures. Accuracy in these tasks will ensure the use of sound business practices by RIT as well as its compliance with applicable laws and regulations.
- Appropriate Use of University Resources
As the recipient of donations, government and private grants, and other contributions, the university strives to be an effective steward of its resources. All members of the RIT community should work to protect university property, financial assets, and other resources as appropriate. Consistent with other specific policies, members of the RIT community should not waste university resources or use them for personal benefit or for the benefit of a non-university entity. For purposes of applying this Code, “use” consistent with other RIT policies shall not be construed as waste of university resources. Further, university resources are defined to include, but not be limited to, the following:
- University records, including student records;
- Any tangible or intangible asset, including currency;
- Intellectual property rights, including the university’s information technology infrastructure;
- Computer software, hardware, and related technology;
- Rights or claims against third parties;
- Facilities and the rights to the use of university facilities;
- The university’s name, logos, and trademarks; and
- Real property.
- Community Health and Safety
RIT is committed to protecting the environment, health, and safety of its community and ensuring the security of university premises and facilities. The university and the RIT community must observe all applicable regulations, standards and policies, and must adhere to sound practices relating to matters of physical safety, and environmental health and safety. Individuals should report promptly any threat or risk to health or safety and should take reasonable steps to promote physical security of themselves and other members of the RIT community.
- Information Privacy, Confidentiality, and Security
By law and contract the university is the custodian of confidential, proprietary, and private information. Individuals who have access to such information are expected to treat this information carefully by observing applicable laws and RIT policies and procedures for obtaining, securing, maintaining, handling, divulging and destroying this information. Furthermore, all members of the RIT community must limit their use of such information solely to the purpose for which access to the information was granted.
C. Reporting Violations
All members of the RIT community are expected to raise any questions or report any violations of this policy and code, other RIT policies, or any federal, state, local law, or regulations, as they normally would to:
- Immediate supervisors, deans, division heads, or an appropriate university officer, or in addition, to the chief risk and compliance officer.
- The RIT Ethics Hotline by calling (866)294-9358 or (866)294-9572 TTY; and/or logging into the online reporting website available at http://finweb.rit.edu/svp/ethics/. This hotline is not intended to replace or supersede any existing reporting methods or protocols, and it is not to be used to report academic matters, or any health, fire, or safety emergencies.
D. Investigations of Potential Violations
After a possible violation of this policy and code, RIT policies, any federal, state, local law, or regulation is brought to RIT's attention, RIT will promptly and thoroughly investigate the matter to the extent necessary and appropriate by its usual process as it has and would for any other breach of its policies. RIT may use any internal or external consultant to assist in such investigation. Consistent with other applicable RIT policies involving faculty, staff, and students, disciplinary measures may be taken as a result of such investigation, up to and including discharge from the RIT community.
E. Whistleblower Protection Against Retaliation
RIT will not tolerate retaliation toward, or harassment of, anyone who reports actual or perceived violations of this policy and code, compliance with any law, regulation, or RIT policy. Any member of the RIT community who has been found to have taken retaliatory action against another who reported potential wrongdoing will be subject to discipline, up to and including discharge from the RIT community. Likewise, RIT will not tolerate abuse of this or any other process by either party. These provisions in section C (above) and herein shall constitute RIT’s Whistleblower policy.
Responsible Office: Global Risk Management Services and specifically RIT's chief risk and compliance officer.
Effective Date: Approved December 9, 2009
Edited August 2011