Code of Conduct
This Code of Conduct Policy describes standards to guide us in our daily business activities as they relate to accounting, internal control, and auditing matters. We believe these standards are already being followed. Our goal is to commit them to writing, and to insure that they are understood and followed by the community.
The Code of Conduct Policy applies to all employees (faculty and staff) of Loyola University Chicago (University) operations including officers, faculty, staff, and individual who perform services for the University as volunteers. The Policies refer to all these persons collectively as “members of the University community” or “community members.”
These policies do not alter or supersede additional policies in place that may be more restrictive or specialized (e.g., Loyola University Health System, sponsored programs, financial aid and student loans).
Employee Integrity and Ethical Conduct Policy
The University is committed to the highest ethical and professional standards of conduct as an integral part of its mission, the promotion of learning. To achieve this goal, the University relies on each community member’s ethical behavior, honesty, integrity and good judgment. Each community member should demonstrate respect for the rights of others. Each community member is accountable for his/her actions with respect to accounting, internal controls and auditing issues.
Compliance with Laws and University Policies
The University and each community member must transact University business in compliance with all laws, regulations, and University policies related to their positions and areas of responsibility. Understanding and following these standards can be complex, such as in areas of procurement (including limitations on the ability to contractually bind the University) and employment matters.
In addition, community members are expected to behave in a manner which respects the freedom of others as well as refraining from interfering with, obstructing or disrupting a normal University activity, even while exercising their own freedom of expression. Managers and supervisors are responsible for teaching and monitoring compliance in their areas.
Under Section 301 of Sarbanes Oxley, the University Audit Committee must take responsibility for ensuring that processes are in place for the receipt, retention and treatment of any complaints about accounting, internal controls and audit issues. Channels must be open for employees to communicate their knowledge of malfeasance or errors regarding these issues without fear of management retaliation.
Reporting Suspected Violations or Concerns about Accounting, Internal Controls and Auditing Issues
The University’s compliance efforts focus on teaching members of the University community the appropriate compliance standards for the areas in which they work. Nevertheless, violations may occur. In addition, members of the University community may have concerns about matters that they are not sure represent violations. This section describes community members’ responsibilities for reporting violations or concerns, and how these responsibilities may be carried out.
Each community member is encouraged to report violations or concerns about violations or concerns about accounting, internal controls and auditing issues that come to his/her attention. Managers have a special duty to adhere to the standards set forth in this code, to recognize violations, and to enforce the standards. Disciplinary actions for proven violations of this code of conduct or for retaliation against anyone who reports a possible violation will be determined on a case-by-case basis and may include termination of employment. Individuals who violate the code may also be subject to civil and criminal charges in some circumstances where a law or laws may have been broken.
How to Report a Violation or Discuss a Concern about Accounting, Internal Controls and Auditing Issues
- You may report violations or concerns about accounting, internal controls, and auditing issues to your immediate supervisor or department head, if appropriate or use the EthicsLine Reporting Hotline to report violations or concerns.
- In the event of violations or concerns that you or your immediate supervisor or department head may have, you are responsible to contact Loyola’s Chief Financial Officer (CFO), the Vice President for Human Resources (CHRO), or use the EthicsLine Reporting Hotline for resolution of a possible violation or concern.
Any matters resulting in violations of accounting, internal controls, and auditing issues will be reported to the President and the Audit Committee of the Board of Trustees.
The University strongly encourages all faculty, administrators, staff, and students to report suspected or wrongful acts conduct by Loyola University Chicago employees through the offices listed above for such reporting.
No University faculty member, administrator, staff or student may interfere with the good faith reporting of suspected or actual wrongful conduct; no individual who makes such a good faith report shall be subject to retaliation, including harassment or any adverse employment, academic or educational consequence, as a result of making a report. The University will take whatever action is necessary and appropriate to address a violation of this policy.
Reviewed: 01/17/2017; 06/27/2019
The purpose of this policy is to avoid favoritism, the appearance of or potential for favoritism, and conflicts of interest and loyalty often associated with nepotism. Nepotism is inconsistent with the University’s longstanding policy of making employment decisions and other business decisions based solely on University needs and individual qualifications, skills, ability and performance.
No University employee (faculty or staff), volunteer, or vendor may make, participate in, or attempt to influence employment or other business decisions involving a relative or pressure or cause others to do so. Therefore, there can be no direct reporting or supervisory relationship between relatives. For any situation which may have existed prior to the development of this policy, if an individual was assigned to a position that is under the supervision or control of a relative, who has or may have a direct effect on the individual’s progress or performance, or an individual is to be assigned to a position with the same immediate supervisor as a relative, a management plan must be devised and approved by the head of the organizational unit (e.g., Dean or Director) and Human Resources.
A management plan is also required when an individual already assigned to a position becomes a relative of a supervisor, subordinate, or someone who works for the same immediate supervisor.
The purpose of the management plan is to outline supervision and evaluation procedures that will mitigate possible conflicts of interest. The management plan must address reporting relationships, supervision, and evaluation that will assure that there will be no decision making based upon relationships between relatives in promotion, compensation, hours, or other conditions of employment or in any approvals required for the expenditure of University funds or the use of University resources. The plan should address the management of the approval and review process to preclude any potential appearance of nepotism, conflict of interest, or conflict of commitment. To ensure continuity and appropriateness, a unit review of the approved management plan should take place in the event of any change in reporting relationships, and on an annual basis at a minimum.
Members of an Audit Team
No relative of any University faculty member, staff, any other employee or volunteer may serve on any audit team (either Internal Audit or external auditors) which provides auditing services to the University.
- Nepotism: Favoritism in the workplace based on kinship, which ordinarily consists of making employment or other business decisions based on a family relationship.
- Employment Decisions: The full spectrum of employment or volunteer related actions, including but not limited to decisions related to hiring, supervision, direction of work, promotion, compensation, work/volunteer hours, performance evaluation, termination and all other terms and conditions of employment or volunteer related actions.
- Business Decisions: Decisions related to the full spectrum of University commercial activities (e.g., buying, hiring, selling, contracting, licensing, leasing) or otherwise involving the expenditure of University funds or the use of University resources.
Relative: the spouse, domestic partner, anyone in a romantic relationship and, whether by blood, adoption, marriage or domestic partnership, the child, parent, grandparent, sibling, grandchild, aunt or uncle, niece or nephew, or any person residing in the immediate household (or the household of the spouse or domestic partner of any of these relatives) of the University employee, or his or her spouse or domestic partner, or person in a romantic relationship.
- This policy does not prohibit (but does not encourage) the University from simultaneously employing relatives or engaging in commercial activities with the relatives of employees. For example, relatives are permitted to work in the same University department or unit so long as the relatives comply with the requirements outlined above (e.g., there is no direct reporting or supervisory relationship between the relatives and all employment decisions are made by others).
- This policy is in addition to the University’s Conflict of Interest Policy. If a University employee’s relative is also employed by the University, volunteers at the University, or engages in commercial activities with the University, the relationship should be disclosed in the annual conflict of interest disclosure form.
- Employees and volunteers must self-report in writing to the head of their organizational unit before they make, participate in, or attempt to influence (or cause others to make, participate in, or attempt to influence) decisions covered by this policy. If the relationship involves the leader of an organizational unit (e.g., a Director), the report must be made in writing to the next most senior leader to whom the employee is accountable.
- This policy applies to instances of nepotism that existed before the enactment of this policy. Any existing relationships or situations must be disclosed immediately, evaluated, and managed as provided in this policy.
- Legitimate issues may arise and thus must be disclosed and managed under this policy with regard to: (i) relatives who do not fit the definition of relative provided above; or (ii) situations where the employee or volunteer is directly or indirectly involved in the University’s engagement or potential engagement (e.g., as a contractor) of a relative.
- The fundamental goal of the management plan is to mitigate actual and perceived favoritism and conflicts of interest and loyalty by establishing appropriate processes for employment decisions or volunteer related actions. Depending on the employment classification (e.g., staff or faculty) of the individual with whom the employee or volunteer has a relationship, a management plan should be devised by, as appropriate, the unit’s academic affairs administrator, or Human Resources, and must be approved by the head of the organizational unit (e.g., Dean, Director, Chairperson). At a minimum, management plans must: (i) address reporting relationships, supervision, and evaluation in a way that will assure that there will be no participation in employment decisions or volunteer related actions as prohibited by this policy and (ii) establish a review and approval process for expenditures to sufficiently mitigate or preclude favoritism or the appearance of favoritism. To ensure continuity and appropriateness, periodic review and, as needed, revision of the approved management plan should occur at least annually and also whenever there is a relevant change in reporting relationships. If the relationship involves the leader of an organizational unit, the management plan must be reviewed and approved by the organizational leader to whom that unit leader is accountable.
- Concerns or complaints about possible violations of this policy should be submitted to the VP of Human Resources (CHRO). All such complaints will be treated as confidentially as feasible and will be addressed by the VP of Human Resources (CHRO) or his/her designee. Concerns and complaints may also be reported to the University’s “EthicsLine Reporting Hotline,” a centralized and confidential web/phone reporting system for students, faculty, and staff. The reporting system is available 24/7 for people to file reports either online or by telephone. Anyone wishing to file a report is encouraged to do so via the “EthicsLine” or by phone at (855) 603-6988.
- Violations of this policy may result in discipline up to and including termination of employment.
Revised: 6/17/19 | 9/4/19