������ýҕ�l

2 — SCOPE

This policy applies to all University employees, all of whom are expected to ensure that their conduct is consistent with the statements in Sections 3 through 7 about how the University intends to conduct its business activities. This policy does not derogate from any right that a member of faculty or staff has under a collective agreement.

Disciplinary action, in accordance with applicable collective agreements as appropriate, may be taken for non-compliance with this policy.

3 — COMPLIANCE WITH LAWS, POLICIES AND PROFESSIONAL STANDARDS

We will conduct all our activities in compliance with the law, University policies and applicable professional standards.

4 — CONFIDENTIALITY

We will handle all information given to the University in confidence in accordance with applicable university policies and ethical, legal and professional standards

4.1 Educational Records

We will not disclose Information in an educational record without the student’s consent, which consent may be implied, or as required by law.

4.2 Personnel Information

We will treat salary, benefit and other information relating to employees as private and confidential; maintain personnel files, payroll information, disciplinary matters, and similar information to ensure their confidentiality; and take care to prevent the release of such information beyond those persons who require it to do their jobs. This will be done consistent with the University’s obligations as required by law, including the New Brunswick Right to Information and Protection of Privacy Act (“RTIPPA”).

4.3 Personal Information

We will maintain in confidence personal information provided to the University by anyone including donors, employees, students, potential students, and their families unless the individuals consent to its release or unless the consent may be implied or disclosure required by law. Personal information, as so defined under RTIPPA, will be managed in accordance with this Act. Individuals may contact the Vice President Finance and Administration concerning the application of the Act.

5 — BUSINESS ETHICS

We will carry out our responsibilities in accordance with high ethical standards.

5.1 Honest Communication

We will not knowingly make false statements to students, employees, Regents or those doing business with the University.

5.2 Financial Reporting

We will accurately, clearly and completely represent both orally and in writing the relevant facts and the true nature of any transactions on all financial reports, accounting records, research reports, expense accounts, time sheets, and other financial documents.

5.3 Professional Conduct

We will perform our duties in compliance with any codes of conduct that apply to us because of our membership in a profession.

6 — CONFLICTS OF INTEREST

We will not place ourselves in situations where there are conflicts between our personal interests and the interests of the University.

6.1    Purchases of Goods and Services

We will not purchase goods or services from a supplier who is an employee of the University, or in whom an employee of the University has a significant interest, unless evidence is provided to show that the terms offered by that supplier are of equal value or more advantageous to the University than those terms available elsewhere for equivalent goods or services.

6.1.1 Significant Interest – means a) any relationship which can influence, or which might be seen to influence, the policies of a business; or b) any relationship in which income of an employee is directly affected by sales to the University. Such interest might include, but is not limited to ownership of, or part ownership in, a business; membership on the board of directors of a business or any of the above relationships enjoyed by a member of the employee’s immediate family, defined as parents, brothers, sisters, spouse or partner and children.

6.2    Disclosure

We will disclose any conflicts between our personal interests and the interests of the University such as a significant interest in a business that supplies or may supply goods or services to the University.

6.3    Personal Profit

We will not use our positions to profit or to assist others in profiting at the expense of the University.

We will also not make purchases for exclusive personal use from University and University administered funds.

6.4    Gifts and Gratuities

We will not accept gifts, favours, services, entertainment, or other things of material value in any situation where decisions affecting the University might be influenced.  The receipt by faculty members of textbooks from publishers is not a violation of this statement.

6.5    Supporters of the University

We will enter into contracts for the purchase of goods and services solely on the merits of the transactions, and not for any other reason including the vendor’s relationship with or support of the University.

7 — PROTECTION OF ASSETS

Since the University’s assets are for the benefit of current and future generations of students and faculty, we will strive to preserve, protect, and enhance those assets by making prudent and effective uses of them. We will not commit fraud of any kind, as defined by converting or using those assets for unauthorized benefit or personal gain or depriving the University of a benefit or gain.

7.1    Fraud

Fraud includes, but is not limited to, an act, irregularity or activity that is unethical, dishonest, improper, or illegal such as:Theft, embezzlement, misappropriation, misapplications, destructions, removal, or concealment of University property including but not limited to money, tangible property or University intellectual property

• Forgery, falsification or alteration or inappropriate destruction of any paper or electronic documents (cheques, reference letters, resumes, grant applications, time sheets, requisitions, budgets, accounting records, etc.)
• False claims and/or misrepresentation of information and/or documents
• Inappropriate use of computer systems including hacking and software piracy
• Bribery, personal kickbacks, or personal rebates (given or received)
• Authorizing or receiving payments for goods not received or services not performed
• Authorizing or receiving payments for hours not worked

8 — PROCEDURES FOR QUESTIONING FINANCIAL INFORMATION AND COMPLIANCE WITH THIS CODE

Special emphasis is given to the importance of compliance with this Code and to the accuracy of financial information.

8.1    Duties and Responsibilities

Therefore, all employees directly or indirectly involved in the maintenance, preparation or presentation of financial information, will accept personal responsibility for the accuracy and adequacy of that information.

University managers should be aware of the risks and exposures in their area(s) of supervision and are responsible for the implementation and enforcement of internal controls and policies that will provide for the security and accountability of resources entrusted to them.

Employees are responsible for bringing any matter that they are concerned  may violate this Code, or any financial information, whether in preparation or in final form, that might not be accurate or complete in any material respect,  promptly to the attention of the next appropriate supervisory/management level or to the appropriate dean, director, or vice-president. In the event that that they are not satisfied by the response, the matter should be brought to the attention of the President.

8.2    Confidentiality and Safe Disclosure

All individuals involved in a disclosure or an investigation under this policy shall keep the details and results confidential.

Details or results of an investigation will not be disclosed or discussed with anyone other than those who have a legitimate need to know except as required by law. This is important to preserve the rights of individuals involved in an allegation of ethical misconduct or fraud.

All employees involved in an allegation of ethical misconduct or fraud, whether they are the complainant or the respondent, are to be treated fairly and consistently regardless of their position or number of years employed by the University. These employees have legal rights that must be respected.

In the event that any individual involved in the investigation is requested pursuant to or required by applicable law or summons or order of any court or other authority to disclose any information associated with the investigation, the individual shall forthwith notify the University, in writing of the request or requirement so that the other party may seek a protective order, or in their sole discretion, challenge the disclosure.

Any concerns regarding possible violations of this Code or regarding questionable accounting or auditing matters can be brought directly to the Chair of the Audit Committee at AuditChair@mta.ca or they can be confidentially and anonymously directed in writing addressed to the Chair of the Audit Committee, Mount Allison University, 65 York Street, Sackville, N.B. E4L 1E4 and marked "Confidential Communication". That letter will be delivered to the Chair unopened, and the Chair will ensure that the source of the complaint or concern, if identified in the letter, will not be revealed to University management.

The University will not retaliate against anyone who in good faith raises or helps to resolve an integrity concern at Mount Allison.

Any individual who experiences harassment, threats, retaliation or discrimination as a result of reporting evidence of ethical misconduct or fraud in the context of university functions and / or activities should inform the Director of Human Resources immediately.

9 — POLICY REVIEW AND COMMUNICATION

The Policy shall be reviewed at least every three years and either confirmed or amended. The Controller will ensure all employees are informed of this policy on a regular basis. Usually that will be done by circulating the policy in an annual email from the Chair of the Audit Committee.