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Code of Conduct

CODE OF CONDUCT

Application

This Code of Conduct Policy (the "Code ") applies to all staff (hereinafter referred to as “employees”) of Point Park University (the "University"). The Code applies to all employee decisions and activities within the scope of employment, or when representing the University in any capacity. A copy of the Code will be provided at orientations for new employees. Existing employees will be asked to review the Code each time it is amended, or at least annually. All University supervisors should be familiar with the requirements of the Code, and should encourage employees to apply the Code to their daily activities and decisions, and to seek guidance from the appropriate individuals when additional information or explanation is needed.

Copies of the Code may be obtained from the Assistant Vice President of Human Resources. The Code will also be referenced in any staff handbooks and can be found on the University’s website.

Purpose and Principles

As members of the Point Park University community, employees are responsible for sustaining the highest ethical standards of this institution, and of the broader community in which we operate. Individuals acting on behalf of the University have a general duty to (i) conduct themselves in a manner that will maintain and strengthen the public's trust and confidence in the integrity of the University, (ii) take no actions incompatible with their obligations to the University, and (iii) conduct themselves in accordance with the principles set forth herein.

Each University employee shall:

1. Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal interests and the interests of the University.

2. Maintain an ongoing commitment to honesty, trustworthiness and responsibility by acting in a reliable and dependable manner, and by treating others with impartiality

3. Act as stewards of University property and resources by exercising custodial responsibility and appropriate care and maintenance over such property.

4. Provide fair, accurate, timely, and understandable information in any report, press release, marketing and advertising materials, or any other materials shared with the general public, governmental agencies or other persons or entities with which the University has dealings.

5. Comply with the laws of federal, state and local governments that are applicable to the University, and the rules and regulations of private and public regulatory agencies that have jurisdiction over the University.

6. Protect the confidentiality of non-public information about the University and its students, including, but not limited to, student records, employee personal or medical files, and contracts and agreements with third parties, in order to prevent the unauthorized disclosure of such information. This does not prohibit employees from disclosing and discussing their own or other employees’ terms and conditions of employment.

7. Promptly report any suspected violation of this Code to the University's Assistant Vice President of Human Resources, or as otherwise provided for herein.

Ethical Standards

High ethical standards depend ultimately on a climate that encourages them. An abiding spirit of high ethical standards never can be supplied by a piece of paper. The University takes pride in the ethical spirit of its employees and continues to rely upon the actions of the employees to make the University a trusted and respected member of the community. The mere appearance of misconduct or impropriety can be damaging to the University, therefore, the University and its employees must strive at all times to maintain the highest standards of quality and integrity.

University employees must conduct all business on behalf of the University in a professional, honest and ethical manner and must adhere to these standards when dealing with the University's students, parents, vendors, and each other. University members must not make false or misleading statements to any entity doing business with the University, or to any student, employee, law enforcement personnel or representative of any governmental or quasi-governmental entity.

Confidential and Proprietary Information

Community members receive and generate on behalf of the University various types of confidential, proprietary and private information, including, but not limited to, student records, employee personnel and medical files, contracts and agreements with third parties, business plans, University policies and procedures, security, methods of doing business, computer software and databases, trade secrets, research, inventions and other intellectual property interests of the University or its employees or students. This information is not to be disclosed to anyone outside of the University or used directly or indirectly for personal benefit or for the benefit of any third party who is not entitled to such information. Moreover, it is essential for the operation of the University that each University employee comply with all federal laws, agreements with third parties, and University policies and principles pertaining to the use, protection and disclosure of such information, and such obligations shall apply even after the University employee's relationship with the University ends. Nothing in this policy prohibits employees from disclosing and discussing their own or other employees’ terms and conditions of employment.

In accordance with the Family Educational Rights and Privacy Act (FERPA) student information contained in educational records is generally prohibited from being released to third parties without the student's written consent.

University employees shall treat as confidential all personal files, payroll records, disciplinary records and all other similar information relating to its employees. This information will not intentionally be shared with anyone, except with those who need access to such information to perform their job responsibilities.

University employees shall treat as confidential and protect personally identifying information of students, potential students and their families, including social security numbers, birth dates, credit card numbers, bank account locations and other similar financial information. University employees shall comply with all federal, state and local laws in connection with this obligation (including, but not limited, the Gramm Leach Bliley Act, as applicable).

Conflict of Interest

As an institution, the University is judged not only on the collective actions of University employees, but on their individual actions as well. Accordingly, each University employee must manage his or her personal and business affairs legally and ethically, and so as to avoid situations that might lead to a conflict or the suspicion of a conflict between his or her self-interest and his or her duty to the University, our students and the public in general. University employees' primary professional allegiance shall be to the University and its mission to promote education, research and scholarship. A potential or actual conflict of interest exists when a University employee’s obligations to the University may be compromised by their other interests or commitments, especially economic, and specifically when those interests or commitments are not disclosed. Although not all conflicting interests are prohibited, those involving the potential for self-gain or gain by a third party to whom the University employee is related can undermine the judgment or objectivity of the University employee, resulting in compromise to the primary obligation to the University. In addition, bias or the appearance of bias may undermine community trust in the University.

Full-time University employees shall not, without approval of the President perform or render services to any competitor of the University, or with any entity with which the University conducts business or seeks to conduct business, which may conflict with the employee’s obligations and responsibilities to the University. All University employees must obtain permission from the President before they may take a position on the Board of Trustees or Directors of any entity whose interest may conflict with the University.

University employees are prohibited from accepting, from third parties (including staff, faculty or students) gifts, favors, services or anything of value in a situation where decision-making or actions affecting the University may be influenced. University employees are prohibited from providing, to third parties (including staff, faculty or students) gifts, favors, services or anything of value in a situation where decision-making or actions affecting the third party recipient may be influenced. Notwithstanding the previous, gifts of nominal value, or gifts customarily given and generally viewed as appropriate in the business, may be accepted without violation of this provision. University employees shall exercise good judgment in making this determination, and should seek additional guidance in the event there is any question as to whether a particular gift violates this policy.

In order to protect the University mission, University employees with other professional or financial interests shall disclose them. The University strongly encourages employees to disclose to the appropriate dean or department head, VP or department director, their outside commitments on a regular basis (e.g., during annual departmental reviews, evaluations, or whenever those commitments undergo significant change.) In the event that potential conflicts cannot be resolved at this level, they should be referred to the Assistant Vice President of Human Resources.

Financial Reporting

All University accounts, financial reports, tax returns, expense reimbursements, time sheets and other documents, including those submitted to governmental agencies, must be accurate, clear and complete. All entries in University books and records, including departmental accounts and individual expense reports, must accurately reflect each transaction. All University employees shall fully comply with any and all guidelines and best business practices implemented by the Audit Committee from time to time. University employees are prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead the University's independent public auditors for the purpose of causing the financial statements of the University to be misleading.

Compliance with Laws

All University employees must transact University business in compliance with applicable federal, state and local laws, regulations, and University policy and procedure. Only individuals who have authority delegated by an appropriate University official are authorized to enter into agreements on behalf of the University that create binding legal obligations on the University. University employees must adhere to good health and safety practices and ensure compliance with all environmental health and safety laws and regulations. University employees must not engage in criminal activities.

University employees must refrain from activities that might endanger the University tax-exempt status, including lobbying and political activities. University employees, as private citizens, may participate or contribute to political campaigns or organizations, but must do so as individuals and not as representatives of the University.

University employees must conduct all business with government bodies in an ethical and professional manner, and in accordance with all federal, state and local laws. Any attempt by a University employee to influence a governmental entity in an unlawful manner, whether by an offer of any benefit, or otherwise, is strictly prohibited.

Discrimination

No University employee shall discriminate on the basis of race, color, national origin, sex, age, religion, ancestry, disability, veteran, sexual orientation, genetic information, marital, caregiver status, familial status, or any other characteristic protected by applicable federal, state, or local law, in its administration of educational programs or activities, or with respect to admissions or employment in accordance with State and Federal laws. University employees shall take reasonable measures to ensure that all contractors and suppliers of materials or services to the University comply with applicable antidiscrimination laws so long as such third parties are engaged in a business relationship with the University.

Use of University Resources

University resources must be reserved for purposes of the University and used in furtherance of the University mission. They may not be used for personal gain, and may not be used personally at all except in a manner that is incidental and reasonable in light of the University employee's duties. University employees shall act as custodians of University property and shall take steps to see that the necessary maintenance is performed to ensure the integrity of University property for future generations of employees.

Reporting Suspected Violations

1. Reporting

Those acting on behalf of the University shall seek appropriate guidance when faced with ethical dilemmas. Please contact the University's Assistant Vice President of Human Resources for guidance or to report a suspected violation of this Code, except as set forth below. In the event that a suspected violation arises out of conduct by an individual or individuals in the human resources department, such potential violations should be directed to the University President's office. In the event that a suspected violation arises out of conduct by an individual or individuals in the President’s office, such potential violations should be directed to the Chairman of the Board of Trustees.

2. Confidentiality

Reports of suspected violations of this Code will be handled with discretion, and shared only on a need to know basis. Reports may be made anonymously.

3. No Retaliation

Retaliation against anyone for reporting an actual or suspected violation of this policy is prohibited and will not be tolerated.

4. Cooperation

All University employees are expected to cooperate fully in the investigation of any alleged violation of this Code

5. Discipline

Failure to comply with the University’s Code and policies could result in disciplinary action, up to and including termination. The severity of the discipline depends on the nature of the violation.

Conclusion

This Code, while it does not provide exhaustively specific detail of what one should and should not do, is intended to communicate the University's overall expectations of proper conduct and what professional conduct the University values from its employees. The Code is intended to reinforce the principle that each and every one of us, including University officials and the Board of Trustees, has a responsibility to help ensure that Point Park University conducts its business and pursues its mission in a legal and highly ethical manner.