Code of Conduct

Application

This Code of Conduct Policy (the "Code") applies to all Board of Trustee members, and officers with a title of vice president or higher of Point Park University (the "University"). The Board of Trustee members and the university officers with a title of vice president or higher of Point Park University shall collectively be referred to as the "University Officials".

Purpose and Principles

As members of the Point Park University community, the University Officials 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 Official 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 that the University has dealings with.
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 files, and contracts and agreements with third parties, in order to prevent the unauthorized disclosure of such information.
7. Promptly report any violation of this Code to the University's human resources director, or as otherwise provided for herein.

The University Officials are on notice that they will be held accountable for their adherence to this Code and that their compliance with the standards and policies set forth herein are an integral part of their responsibilities with the University.

A waiver to any provisions of this Code shall be granted only by the University's Board of Trustees.

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 University Officials and continues to rely upon the actions of the University Officials 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 the University Officials must strive at all times to maintain the highest standards of quality and integrity.

University Officials 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 attorneys, consultants and auditors. 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 files, donor information, 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 Official 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 Official's relationship with the University ends.

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 Officials shall treat as confidential all personnel 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 Officials 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 Officials 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 the University Officials, but on their individual actions as well. Accordingly, each University Official 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 Officials 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 Official's obligation 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 Official is related can undermine the judgment or objectivity of the University Official, 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.

University Officials shall not, without approval of the Board of Trustees, 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 University Official's obligations and responsibilities to the University. University Officials must obtain permission from the Board of Trustees before they may take a position on the Board of Trustees or Directors of any entity whose interests may conflict with the University.

University Officials 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 Officials 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 Officials 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 Officials with other professional or financial interests shall disclose them to the Board of Trustees.

All University Officials are obligated to sign a conflict of interest statement which has been separately adopted by the Board of Trustees, and the University Officials acknowledge and agree that they will be required, on an annual basis, to reaffirm their obligations under the conflict of interest statement.

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 Officials shall fully comply with any and all guidelines and best business practices implemented by the Audit Committee from time to time. University Officials 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 rendering the financial statements of the University misleading.

Compliance with Laws

All University Officials 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 Officials must adhere to good health and safety practices and ensure compliance with all environmental health and safety laws and regulations. University Officials must not engage in criminal activities.

University Officials must refrain from activities that might endanger the University tax-exempt status; this includes lobbying and political activities. University Officials, as private citizens, may participate or contribute to political campaigns or organizations, but must do so as an individual and not as a representative of the University.

University Officials 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 Official to influence a governmental entity in an unlawful manner, whether by an offer of any benefit, or otherwise, is strictly prohibited.

Discrimination

No University Official shall discriminate on the basis of race, color, national origin, sex, age, religion, ancestry, disability, veteran, sexual orientation, marital or familial status in its administration of educational programs, activities, or with respect to admissions or employment in accordance with State and Federal laws. University Officials 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 for personal use except in a manner that is incidental and reasonable in light of the University Official's duties. University Officials 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 faculty and staff.

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 human resources director 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 from 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 of the President, such potential violations should be directed to the Chairman of the Board of Trustees or a member of the executive committee of the Board of Trustees.

2. Confidentiality

Such reports may be made confidentially and anonymously. A Report of potential violations to the University will not in itself jeopardize the employment of the individual being reported.

3. Cooperation

All University Officials are expected to cooperate fully in the investigation of any misconduct.

Conclusion

This Code is not an attempt to define specifically what one should and should not do, but to communicate the University's expectations of proper conduct and what professional conduct the University values from the University Officials.