ºÚÁÏÇ鱨վ

Originator: Office of Legal Affairs

Subject: ºÚÁÏÇ鱨վ Contractor Code of Ethics

1. Purpose

   As a federal contractor, ºÚÁÏÇ鱨վ (ºÚÁÏÇ鱨վ) must maintain high ethical standards and comply with all applicable laws, rules, and regulations. Adherence to this Code is required for ºÚÁÏÇ鱨վ as a federal contractor in accordance with Federal Acquisition Regulation (FAR) 52.203-13 Contractor Code of Business Ethics and Conduct.

2. Definitions

   1. Code: The Contractor Code of Ethics.
   2. Compliance Program: ºÚÁÏÇ鱨վ's written procedures and practices that are designed to ensure all employees are aware of its Contractor Code of Ethics and adhere to its standards.
   3. Employee: Any person employed by ºÚÁÏÇ鱨վ, including all faculty and staff, regardless of division or employment status.
   4. Overseas Employee Code of Conduct: The Code of Conduct that applies to all employees assigned to or visiting ºÚÁÏÇ鱨վ's overseas divisions (both in Asia and Europe). This Code of Conduct is available on the overseas divisions' intranet sites and copies can be received by contacting the Office of the Senior Vice President for Overseas Operations.

3. Employee Obligations Under the Code

   Employees must comply with this Code and if they do not, they may be subject to disciplinary action, up to and including termination of their employment with ºÚÁÏÇ鱨վ. Specific Obligations all employees have under this Code include the following:

   1. Duty to Report: All employees have a duty to report all suspected violations of the Code or other potentially unethical behavior by anyone, including other employees and contractors. Reports may be made to ºÚÁÏÇ鱨վ's Office of Legal Affairs at legal-affairs@umgc.edu. Anonymous reports may be made to .
   2. Compliance with Laws: All employees are required to follow all federal, state and local laws applicable to them during their employment with ºÚÁÏÇ鱨վ. This includes, but is not limited to, criminal laws regarding fraud, conflicts of interest, and bribery.
   3. Discrimination/Harassment Prevention & Elimination: ºÚÁÏÇ鱨վ's Policy and Procedures on Affirmative Action, Equal Opportunity and Sexual Harassment was established to prevent or eliminate discrimination and/or harassment in accordance with due process while protecting the rights of our students, faculty, and staff. Under this Policy and Procedures, employees are required to fully cooperate with any investigations of alleged discrimination and/or harassment. If an employee fails to do so or provides false information during an investigation, the employee may be subject to disciplinary action, up to and including termination of employment. See ºÚÁÏÇ鱨վ Policy VI-1.00 - Non-Discrimination and Anti-Harassment.
   4. Drug-Free Workplace: All ºÚÁÏÇ鱨վ employees are subject to the University System of Maryland's Policy on a Drug-Free Workplace. In accordance with this Policy, ºÚÁÏÇ鱨վ's workplace should be free from the illegal possession or distribution of controlled substances. In addition to any legal penalties that may be applicable to employees, they will also be subject to disciplinary action if they violate .
   5. Conflicts of Interest: Employees are obligated to avoid situations and activities which could conflict with their employment at ºÚÁÏÇ鱨վ. Employees must also comply with the Maryland Public Ethics Act. This includes the following:
      1. An employee may not participate in a matter involving a company or other business entity in which he or she or certain relatives (spouse, father, mother, sister, brother, or child) have a legal or financial ownership interest.
      2. An employee may not participate in a matter involving a company or other business entity in which he or she or certain relatives (spouse, father, mother, sister, brother, or child) are employed or may be employed.
      3. An employee may not have a financial interest in, or be employed by, an entity having or negotiating a contract with ºÚÁÏÇ鱨վ. This includes serving on a private board of directors, even if there is no compensation for this service.
      4. An employee may not hold any secondary employment relationship that would impair the employee’s impartiality and independence of judgment.
      5. An employee may not intentionally use the prestige of his/her employment or of ºÚÁÏÇ鱨վ for his/her own private gain.
      6. Miscellaneous unsolicited gifts of a nominal value, not including cash and gift cards, may be accepted by employees. However, an employee may not solicit gifts and may not knowingly accept any gift, directory or indirectly, if it would result in an actual or a perceived conflict of interest. This could be when the gift is from any person whom the employee knows or has reason to know:
         1. 1. is doing or seeking to business of any kind with ºÚÁÏÇ鱨վ,
            2. is engaged in activities that are controlled by ºÚÁÏÇ鱨վ,
            3. has financial interests that may be substantially affected in a specific way by the employee, or
            4. is a lobbyist with respect to the matters within ºÚÁÏÇ鱨վ's functional jurisdiction.
      7. An employee may not disclose confidential information acquired during his/her employment for his/her own or another's economic benefit.
   6. Confidentiality: Employees may require access to confidential, personal information in order to perform their job duties. This information may include confidential student and/or employee records and other documents which contain personally identifiable information (PII), collectively referred to as "Confidential Information". With respect to Confidential Information, employees have the following obligations:
      1. Employees shall ensure that they comply with allÌý applicable ºÚÁÏÇ鱨վ and USM policies, procedures, and practices concerning theÌý confidentiality of records and PII.Ìý ThisÌý includes ºÚÁÏÇ鱨վ's overseas divisions are also obligated to abide by this Code of Conduct.
      2. Supervisory Employees: In addition to the obligations already stated in this Code, supervisory employees:
         1. Shall ensure that the employees they supervise are acting in a manner consistent with this Code, and
         2. Shall not direct the employees they supervise toÌý participate in, approve or tolerate any violation of any provision of this Code.

   7. Additional Information About Code
      For additional information about this Code, please contact the Office of Legal Affairs at legal-affairs@umgc.edu