Code of Conduct and Ethical Standards

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code of conduct
and ethical
standards

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message from the president
code of conduct and ethical standards
The University of Vermont values a strong ethical culture. Our motto “Studiis et Rebus
Honestis” (Integrity in Theoretical and Practical Pursuits) represents the University’s
commitment to honesty and integrity. As members of the University Community, we hold
ourselves to the highest ethical standards and aspire to act in accordance with the values of
integrity and openness stated in “Our Common Ground.” I share these values and support
our institutional efforts to uphold them. I also fully endorse this Code of Conduct and Ethical
Standards.
Although we all strive to do the right thing, there are some situations in which the right course
of action may not be clear. The Office of Compliance Services is available to provide advice
or counsel when questions arise. As an additional resource, the Ethics and Compliance Reporting and Help Line
enables concerned employees to safely and, if the employee wishes, anonymously voice their compliance concerns,
seek compliance guidance, or report suspected wrongdoing.
We all share in the responsibility to comply with University policies, meet legal obligations, and conduct ourselves in
accordance with the ethical values expressed in “Our Common Ground.” Our conduct contributes significantly to public
trust in our institution and to our reputation for quality and excellence. While the Office of Compliance Services
oversees the day-to-day operation of the University compliance program, compliance is everyone’s responsibility. By
working together, supporting each other, communicating concerns and seeking guidance when the right course of action
is unclear, we all can exemplify our motto as we pursue with integrity all that we do.

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introduction
reporting, non-retaliation & disciplinary action
health, safety & campus environment
fiscal compliance & asset management
research
freedom of expression
conclusion – resources, policy references, related documents & contacts
table of contents
(to skip to a particular section, click on the link below)
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code of conduct and ethical standards

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introduction
“Integrity is doing the right thing
even when nobody is watching.”
-C.S. Lewis, Novelist, Academic
(1898 – 1963)

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5
Much of what we need to know about compliance risks is intuitive. However, recognizing risks can sometimes be
more difficult than it seems.
introduction: what?

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code statement
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Both UVM’s motto and “Our Common Ground” illustrate the
University’s commitment to strengthening our culture of compliance.
As a member of the University community, we all need to be aware
of our own conduct and how that affects the University as a whole.
We are all expected to perform our jobs and to
conduct university business ethically and in
Compliance with the laws, acts, statutes, regulations and policies and procedures that
pertain to our jobs. We all have a responsibility to the University, to those
we serve, to our community and to each other.
An effective compliance program will take us from being reactive when a violation is uncovered to
being proactive and preventing the violation from happening in the first place. In other words, if you
read, understand and follow this code, you can go from having to stomp out forest fires to blowing out
a match.
introduction: what?

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reason for the code
7
The goal of a compliance program is to get everyone behaving ethically at all times
and in all situations. Your code of conduct is one tool that you can use when you
are faced with a difficult situation, an ethical dilemma or when you’re not sure what
the right decision is.
Very few people show up to work with the intent to break the law. Sure, it does happen,
but most people want to do the right thing. Regardless of what our individual roles are
at UVM, we may be faced with an ethical dilemma or may just need clarification on a
regulation, law, policy or procedure. That is what your code of conduct is designed to
help with. It’s why the Board of Trustees stands behind the code and why having an
effective compliance program is so important to the mission of the University.
We all have a responsibility to do the right thing, even when nobody is watching. We owe this to each other and to those that we serve.
Most importantly, we all need to recognize that we are all in this together.
While it is impossible to list out every dilemma or difficult situation that could arise, there are some areas that are more risky to the
University. At the very least, we should all be aware of those areas of highest risk within our jobs. Your manager or supervisor should be
able to provide you with guidance in these areas. This code can help you find the answers.
introduction: why?

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applicability of the code
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Your code of conduct and ethical standards applies to all University of
Vermont personnel.
For the purpose of this code, personnel means faculty, staff, volunteers,
student employees, and anyone hired or contracted to perform duties that
are generally associated with an employment relationship (such as a
temporary employee or a graduate student that is getting paid through
the University).
Anyone considered University of Vermont personnel should read the
code. If you read it and don’t understand something, please ask.
Contact your manager or supervisor or any member of the Office of
Audit & Compliance Services with questions or for clarification.
introduction: who?

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applicability of the code
9
If the code applies to you, you must comply with the requirements in the code. There are some common excuses
for non-compliance. Some of the more common “excuses” for non-compliance are:
Regardless of your title or position, these excuses do not justify unethical or illegal behavior. If
you ever feel as if you are being put in a situation to do something illegal or unethical, you have
a place to go for help.
introduction: who?
customary practice
“We’ve always done it this
way.”
expediency
“I didn’t have time.” or “We
don’t have enough staff.”
fear of retaliation
“My manager told me to be quiet and
stop complaining or I’d be fired.”

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office of audit & compliance
services structure
10
Both offices work together but have very
different functions and purposes.
The Director of Compliance Services reports
to the Chief Audit Officer. This provides the
Director with the same independence from
operations that is needed to have an effective
compliance program.
With a direct reporting line to the Board, the
Chief Internal Auditor has independence from
operations and has the ability to bring
compliance issues and risks directly to the
Board.
The Office of Audit & Compliance Services is
structured this way in order to provide both the
audit and the compliance functions the
independence and autonomy needed to run
successful programs.
Chairperson of
the Audit
Committee of the
Board of Trustees
Chief Audit Officer
Director of
Compliance
Services
Office of
Compliance
Services
Office of Audit
Services
introduction: how?
CLICK HERE for more information

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oversight and structure
of the compliance program
Oversight of the program &
responsibility for this code of
conduct:
Office of Compliance
Services
Operational responsibility for most operational
compliance areas:
research, AAEO, finance, risk management &
safety, legal, human resources, information
technology, athletics, privacy, police, facilities
Day-to-day responsibility for actions that could result in a
compliance violation:
YOU
11
The Board of Trustees has a responsibility to take reasonable steps to make
sure the compliance program is effective. The Director of Compliance Services
is the person that the Board has delegated the day-to-day oversight
responsibility to. While the Office of Compliance Services is responsible for
the operation of the compliance program, we are all individually responsible
to be aware of and comply with the legal and regulatory requirements and
with University policies and procedures that apply to our jobs.
In addition, some professions may have additional compliance
obligations through professional organizations or licensing agencies.
In order for your compliance program to work up to its
potential, everyone needs to be an active participant.
Communicate concerns, let someone know when you are
having difficulty following a procedure. Those of us who
are the “doers” are the first ones to recognize a possible
problem. Let someone know.
introduction: how?
Responsible
Official:
President

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code elaboration
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It may be difficult to know at what point you need to report a
concern. Depending on the concern, you may have mandatory
reporting requirements. For example, state law requires that certain University personnel report suspected child abuse. Also, under the
Clery Act which is a federal law, Campus Security Authorities (CSA’s) are required by law to report suspected criminal activity to UVM
Police Services.
Even if not required by a regulation, you may feel a moral or ethical obligation to report something. Under your Code, you are encouraged
to report any suspected wrongdoing.
It is important to understand that not all reports have to be wrongdoing. The compliance reporting mechanisms are also there for you if
you have questions related to a University process, if you need help making a difficult decision or if you are faced with an ethical dilemma.
Sometimes talking it through can help make the situation or the decision easier.
Under your Code, “wrongdoing” means:
• Real or suspected violations of legal and regulatory requirements (laws, acts, statutes,
regulations), policies and procedures and/or professional standards.
• Fraudulent or dishonest conduct resulting in violation of law or University policy.
introduction: when?

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reporting,
non-retaliation
& disciplinary
action “Treat those who are good with
goodness, and also treat those
who are not good with
goodness. Thus goodness is
attained. Be honest to those
who are honest, and be also
honest to those who are not
honest. Thus honesty is
attained.”
-Lao Tzu, Philosopher, Poet
(601 BC– 531 BC)

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compliance reporting
system
14
We all have a responsibility to report violations to any regulations, laws, acts, statutes,
UVM policies, procedures or to this Code of Conduct. Just because ”I am not involved”,
“it doesn’t affect me”, or “it’s none of my business” does not mean we should turn a blind
eye to it. When we become aware of wrongdoing and fail to tell someone, at some level,
we become involved in the wrongdoing.
To assist you with reporting, your compliance program provides you with multiple ways that you can report wrongdoing or suspected
wrongdoing. The University has created a policy called “Whistleblower Policy: Reporting, Protections, & Non-Retaliation” that provides
details on all of the ways you can report.
This does not mean that all reports must come to the Office of Compliance Services. You can report to
the Office of Compliance Services but there is no requirement to do so. If there is another policy that
gives us information on reporting requirements, we should always follow that policy. If there isn’t a policy,
if you’re just not sure where to go or if you’ve reported something elsewhere that hasn’t been addressed,
use one of the compliance reporting mechanisms. While the Office of Compliance Services may not be
the department that handles the report, we will be able to guide you in the right direction. The Ethics &
Compliance Reporting and HelpLine is always available to accept reports of wrongdoing.
Ethics & Compliance Reporting and HelpLine
877-310-0413
reporting, non-retaliation & disciplinary action

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available compliance
reporting mechanisms
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A report may be made using any of the following reporting mechanisms:
1. Use the reporting process identified in the relevant UVM policy or procedure.
2. Report through UVM’s Compliance and Ethics Reporting and HelpLine. This mechanism provides reporters with the
ability to report anonymously.
• Call toll free: (877) 310-0413
• File a report through the web. CLICK HERE or click on the blue button above. You can also go to www.uvm.edu/compliance and click
on the same blue button as above.
3. Report to the Director of Compliance:
• Phone: (802) 656-0847
• Email the Director: CLICK HERE or Email the Department: CLICK HERE
• In writing to: Director of Compliance Services, Office of Audit & Compliance, University of Vermont, 48 University Place, Burlington,
VT 05405
• In person – Office located in Billings, Room 159 (M-F, 8:30am to 4:00pm, additional times available by appointment.
You can always contact UVM Police Services if you believe that criminal activity is taking place or has occurred.
reporting, non-retaliation & disciplinary action

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reporting to managers &
using the helpline
16
For reports made directly to a manager or supervisor, the manager/supervisor is required
to notify the Director of Compliance or the Office of General Counsel when the manager/
supervisor suspects the report may result in either a violation to legal or regulatory
requirements or fraudulent activity. Managers/Supervisors are encouraged to seek the
advice of the Office of Compliance Services as soon as possible when they receive reports
of alleged noncompliance to a legal or regulatory requirement.
Reports made through the HelpLine are received and screened through a third-party vendor. While some other mechanisms accept
anonymous reports, the best reporting method for maintaining the anonymity for anonymous reports is the HelpLine.
Regardless of the reporting mechanism used, all reports are kept as confidential as possible.
However, anonymity can never be guaranteed.
For more information on the HelpLine, refer to the HelpLine FAQ’s. CLICK HERE
Ethics & Compliance Reporting and HelpLine
877-310-0413
reporting, non-retaliation & disciplinary action

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non-retaliation
17
As it relates to your Code of Conduct, retaliation means “taking action to harm someone in response to a report.
Retribution means the act of taking revenge. If you report in good faith or if you participate in an investigation and you
are disciplined, harassed, or otherwise treated poorly because of your report, that is retaliation. And, it’s not OK.
Individuals making bad faith reports do not have this same protection.
At UVM, retaliation is not tolerated. Under federal and state law, whistleblowers have additional protection from
retaliation. It doesn’t matter if it’s a supervisor retaliating against a direct report or peers retaliating against peers.
Retaliation is retaliation and it is not allowed.
Those who retaliate against someone may face disciplinary action up to and including termination from employment. The report does not have to be proven – if
the report was made in good faith and it turns out that wrongdoing did not occur and someone retaliates against the person who made the report, that person
may be disciplined.
reporting, non-retaliation & disciplinary action
Good-Faith Reports
A good faith report is a report that is made with a sincere belief that the issue is occurring, has occurred or
there is a likelihood that it will occur. There is no malice or desire to defraud others. In other words, it is
made with honesty and integrity because you believe it is a problem or could be a problem.
For example, you return to the office after lunch and see your boss in the parking lot taking an envelope full
of cash from someone and sticking it in her purse. You report it. After investigation, it turns out that your
boss just sold a used car and the buyer met her during her lunch to pay for the car.
Bad-Faith Reports:
A bad faith report is a report that is made to deceive, is dishonest, knowingly
untrue or otherwise intentionally misleading. Often times, bad faith reports are
lies intended to get someone in trouble or are untrue and made to retaliate
against someone.
Using the same example except you don’t get along with your boss so you add
in that you’ve seen her do this every week for the past couple of months and
that computers and equipment has been disappearing from your department.

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disciplinary action
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If wrongdoing occurs, those people who were responsible for the wrongdoing
will be disciplined at a level appropriate to the violation. Disciplinary action is
anything from a verbal warning and up to immediate termination. It could also
include termination of University institutional recognition or external affiliate
relationships. Depending on the type of violation and the University’s
regulatory requirements, it could even include civil claims and criminal
charges. There could be violations that the University is required to report to
law enforcement or regulatory agencies. Investigation and determination of
discipline for represented employees will occur in accordance with provisions
of the applicable collective bargaining agreement.
It is important to recognize that we are all in this together and that our actions, or inaction, can have an effect on the
University, on those that we work with and on those that we are responsible to. Disciplinary action is designed to fit the
violation and should be consistent with same or similar violations. Retaliation can take the form of unfair or inequitable
disciplinary action and retaliation is not tolerated at UVM.
reporting, non-retaliation & disciplinary action

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principles
and
standards
The intent of your code is to communicate the principles and
standards that have been identified as most relevant to
UVM’s stated values. This is not a compilation of every
policy that you are responsible to comply with. UVM’s
policies and procedures extend beyond those identified in
this code. Those highlighted here are those that we believe
pose the greatest compliance risk to the University.

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principles & standards #1
health, safety &
campus
environment
“If we are to achieve a richer culture, rich
in contrasting values, we must recognize
the whole gamut of human potentialities,
and so weave a less arbitrary social
fabric, one in which each diverse human
gift will find a fitting place.”
-Margaret Mead, Cultural Anthropologist
(1901 – 1978)

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Under state and federal statutes, it is illegal to discriminate
based on race, color, national origin, religion, sex, disability, certain Veterans, age, citizenship status and genetic
information. The State of Vermont also prohibits discrimination based on sexual orientation, gender identity and related
characteristics, place of birth, ancestry, veteran status, HIV status, and discrimination based on the basis of age as to
persons 18 and older.
A diverse UVM community is in all of our best interests.
It is vital to our ability to achieve academic excellence.
When a university is unsuccessful in creating a diverse
community, the quality of their academic programs
suffers. A diverse community will prepare our graduates
for the ever more diverse world in which they will live
and work.
For more information:
Read UVM’s “Why Diversity” Statement: CLICK HERE
creating a respectful
campus environment
21health, safety and campus environment
“Of all the civil rights for which the world has struggled
and fought for 5,000 years, the right to learn is
undoubtedly the most fundamental.”
-W.E.B. DuBois, Sociologist, Historian and Activist (1868-1963)

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A safe and healthy campus refers to both environmental safety (i.e.,
buildings, grounds) and personal safety. There are many different areas that are covered under the University’s safety program (see
box - the list is not all-inclusive but provides some examples). When it
comes to a safe and healthy campus, we are all equally responsible for
how we behave as well as how we treat others. If you ever feel unsafe or
if you see or hear about unsafe conditions on campus or in your
workplace, let someone know. Contact anyone listed under the resource
section of this Code. If you ever feel that you or someone else is in
immediate danger, call 911.
creating a safe and
healthy campus
22health, safety and campus environment
Examples
• An employee is subjected to sexual harassment by a supervisor.
• A disabled student is unable to access a building.
• A faculty member becomes romantically involved with a current
student in one of his classes.
• You suspect that a co-worker is buying alcohol for an underage
student.
• A University employee is directly responsible for overseeing
minors but has not had the requisite background check or
training.
• A campus security authority (CSA) fails to properly report a crime
that occurred on campus.
• You observe people using external fire escapes or rooftops
without authorization.
• You observe or have knowledge of the improper transfer or
disposal of hazardous materials.

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principles & standards #2
fiscal compliance
&
asset
management
“The time to repair the roof
is when the sun is shining.”
-John F. Kennedy, 35th
President of the United
States (1917 – 1963)

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privacy & security of
confidential information
At the University of Vermont, we recognize the importance of protecting the privacy and
security of confidential information. Some of this information is legally protected. Some of of
the information we need to protect is sensitive and, for a variety of reasons, needs to be kept
confidential. Whether it is legally protected or if keeping it confidential is just the right thing to
do, the University takes this responsibility very seriously and demonstrates its commitment
through its Information Security and Privacy Programs. All UVM personnel have a
responsibility to maintain the privacy and security of confidential or sensitive information.
Protection of this information can greatly reduce the risk of the misuse of information or of a
breach.
24fiscal compliance & asset management
Examples of Legally
Protected Information
• Student Records (FERPA)
• Social Security Numbers
• Financial Account
Information
• Protected Health Information
(HIPAA)
EXAMPLES
• You are behind in some work so you transfer some research data to a USB drive to take home with you over the long
weekend. The data contains the participant’s name, social security number and research results. Your bag that
contained the USB drive is stolen and the data was not encrypted. This is reportable under University policy and under
state law. Contact the Information Security Office at iso@uvm.edu. Remember that removing unencrypted protected
data is not allowed and may also violate contracts, agreements and other federal or state regulations.
• A parent calls and wants information on her child who recently turned 18. The information contains FERPA protected
education records. You cannot disclose the information without the student’s permission. Disclosing without
permission is considered a violation of FERPA.
• You suspect that someone is using your UVM login ID and password to gain access to financial information. Even if
you’re not sure, you should report this to the Information Security Office at iso@uvm.edu.

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PHISHING
Trying to trick a computer
user into giving up their
personal information by
looking like a legitimate
company.
DATA BREACHES
Under Federal and
State law, UVM is
required to report
breaches of personal
information and
protected health
information.
INFORMATION
SECURITY
Working together to
protect our information
systems in order to
reduce the risk of
unauthorized
disclosures or a
breach
privacy & security of
confidential information
Hacking. Phishing. Spam. Adware. Spyware. Trojan
Horses. Malware. Worms. Cookies. Loss. Theft. Social
Engineering. These are all words that in some way, shape,
or form, pose a threat to the University. And, information
is not just an “information technology problem”. It is an
“all of us problem” and we are all equally responsible to
protect against the misuse of information, equipment and
assets of the University.
Anyone with a UVM login and password has responsibility. Those with access to
personal, private, confidential, sensitive or otherwise protected information regardless of
the form or format (electronic, paper, recorded, verbal, etc.) have even greater
responsibility.
As security technology becomes stronger, the “bad guys” are focusing more and more
on trying to get into systems through people. They are getting more savvy with phishing
emails and their use of social engineering. They are masters at tricking people into
giving up their login and passwords. Don’t fall for the trick. If you get an email asking
you to click on a link or asking you to enter your login information, hover over the link to
make sure that it is a uvm.edu address. For more information, visit the IT website –
CLICK HERE.
25fiscal compliance & asset management

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conflicts of interest and
conflicts of commitment
If you, or a member of your immediate family, has (or could have) a personal or financial interest that affects independent judgment as it
relates to University duties OR it could result in personal gain or advancement at the expense of the University, you may have a conflict of
interest. If you engage in activities outside of the University that interfere with your ability to do your job at UVM or it is reasonably
expected that it will interfere with your ability to do your job at UVM, you may have a conflict of commitment. In both cases, the
agreement, arrangement or activity could be prohibited.
26
Special Cases: Gifts and Gratuities
While all UVM personnel are subject to conflicts of interest, only
University officials who have authority and responsibility with
respect to specific commercial contracts, such as those with
service or product vendors, are required to comply with the gift
and gratuity provision. University officials are prohibited from
giving, offering, asking for, or accepting for personal use, any gift
or gratuity from that vendor.
There are exceptions for items of nominal value and certain
circumstances. Check the Conflicts of Interest and Conflicts of
Commitment Policy for more examples.
WHAT IS A CONFLICT?
A conflict of interest is an activity that compromises or appears to
compromise an employee’s judgement in performing the employee’s job
duties.
WHAT SHOULD I DO IF I THINK I HAVE A CONFLICT?
If you are unsure of whether an activity poses a conflict, it is best to err
on the side of over disclosure and report it to your supervisor. While
some conflicts are prohibited, most can be managed via a written
management plan. Certain employees, such as officers of
administration are required to file an annual disclosure statement for
potential conflicts.
fiscal compliance & asset management

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conflicts of interest and
conflicts of commitment
27
Examples of potential general conflicts:
• You hire your uncle for a job in your department even though he doesn’t have the required experience.
• You enter into a contract with your daughter’s company that is valued more than what the contract is
worth.
• You are looking for a vendor and get three quotes from different companies. One of the vendors
approaches you and offers you $500 cash if you choose them. You take the money and choose this
vendor.
• You have a student employee in your department who hears that you need someone to help you with
yardwork at your house. The student approaches you and offers to do this work. You submit extra time
through the University payroll for hours worked doing yardwork at your house.
• You have developed a personal relationship with someone in your department. You allow that person to
take extra days off without submitting sick, vacation or personal hours.
• You take on a side job that interferes with your UVM job. You cancel classes and prioritize the side job but
continue to get paid through UVM as though you are carrying the required course load.
Examples of potential
research/scholarly activity
financial conflicts:
• You have an ownership
interest in a company. You
purchase equipment and
supplies from your own
company without doing any
sort of comparative analysis of
more cost-effective options.
• You provide consulting
services to an organization that
also sponsors your research.
fiscal compliance & asset management

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protecting university assets and
appropriate use of resources
We all have a responsibility to make sure that University resources are not wasted or
used inappropriately. Stealing, committing fraud, bribing, and providing kickbacks are
all examples of inappropriate use of University resources and are all violations of the law,
University policy, this Code or some combination of all three. We must all do our part to
protect University resources.
The University has an obligation to ensure the trust of the public and other stakeholders
through its financial and regulatory reporting. This includes making sure that the records
and reports that you are responsible for filling out are accurate and are finished on
time.
Submitting false information on a timesheet or expense report is stealing. If you know
that information included in a report is false and that report goes to the government,
that is fraud. It is important for all of us to be honest and truthful whenever we fill out
records as part of our work duties.
28fiscal compliance & asset management
accuracy in recordkeeping
Examples
• Creating a phony position in your
department and collecting a salary as
though this were a real person working.
This is referred to as a “ghost position”
and is fraud.
• Using University computers, copiers,
fax machines, and/or office supplies for
your personal business.
Examples
• Providing false information on a job
application.
• Taking the maximum daily travel meal
allowance without incurring the full
expense.
• Submitting extra hours on a timesheet
even though you didn’t work that many
hours. Submitting false information on a
timesheet is no different than stealing.

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Personnel are expected to deal fairly with vendors and other third parties
that UVM conducts business with. No unfair advantage shall be taken of
prospective or current vendors through manipulation, concealment, abuse
of privileged information, misrepresentation of material fact or any other
unfair practice. Additionally, all procurement policies and guidance must
be followed to provide for a fair, impartial and inclusive selection process.
relationships with university vendors and other
third parties in business transactions
29fiscal compliance & asset management
Examples
• Entering into an agreement with a vendor even though you do not have authority to do
so.
• Signing a contract without going through the procurement processes for obtaining and
evaluating vendor quotes and proposals.
• Withholding or reducing payments to a contractor even though the contractor performed
services according to the agreement.
• Using information provided by a consultant without authorization and sharing it as
though it were your own work product.

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principles & standards #3
research
“Research is creating new knowledge.”
-Neil Armstrong, Astronaut (1930-2012)

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research:
regulation & risk
At UVM, the scope of research is broad and diverse. While
research activities are an integral part of the University, it is
also an area that is heavily regulated and, as such, poses significant compliance risks. Ethics are fundamental to all academic
research. Without ethics and trust, a complex, modern research institution cannot function. Researchers must be aware of
the ethical standards governing their discipline and to avoid even the appearance of impropriety.
Research involving human subjects, vertebrate animals or biohazardous materials involves
strict oversight by the institutional review board (IRB) or other oversight committee
assigned to assure compliance with federal rules.
The Research Protections Office provides oversight and support to these review boards and committees and the research
they oversee. More information regarding these protections is on the Research Protections Office website.
CLICK HERE.
31research
human subjects, vertebrate
animals & biohazard materials

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responsible management of government funds
The government has increased its enforcement over effort management and reporting and has imposed multimillion-dollar fines on several
universities. Effort reporting requires that employees accurately report the percentage of the effort they spend working on federally
sponsored research. Taxpayers, like you, fund this research; the public should be confident that their tax dollars are spent as intended.
UVM’s effort management and reporting training tutorial can be found by CLICKING HERE.
The government oversees the export of certain items, software,
technology and services. Determining whether the item or transaction
is subject to export controls requires some time and effort. However,
while the regulations are complex, there are some tools available to
help make the process easier. If you have any questions, you should
contact Sponsored Project Administration at (802) 656-3360.
32research
export controls UVM personnel involved in research activities at any level are strongly
encouraged to enroll in the export compliance modules provided through the
Collaborative Institutional Training Initiative (CITI) Program. Through CITI,
in-depth training regarding export controls is available to UVM personnel.
This site also provides Responsible Conduct of Research training that is
helpful, and sometimes required, of those engaged in Federally-sponsored
research. Visit the SPA website for more information. CLICK HERE
Under both university policy and under various agreements and contracts, the University promises that it will strictly comply with government grants and
contracts terms and conditions and expects its personnel to be knowledgeable about, and comply with, such terms and conditions as appropriate to, and
required by, the nature of their duties. Applicable federal guidance requires institutions of higher education that receive grants or other federal funding to
comply with the regulations and guidelines.

33. page | 33
principles & standards #4
freedom of
expression
“You know life is all about
expression. You only live once,
and you're not coming back so
express yourself.”
Salt -n- Pepa, “Expression”,
Black’s Magic, Next Plateau
Records (1989).

34. page | 34
mission & expectations
While our mission is dedicated to free expression and facilitation of the exchange of
ideas, we need to balance that with our need to ensure that University endorsement
is not improperly attributed and that University resources and facilities are used in
a manner consistent with policy and campus safety.
To this end, the UVM name, logo, seal, letterhead and other indicia of institutional
affiliation (otherwise known as “symbols”) are designed to advance the mission and
reputation of the University in a manner that
reflects its history and purpose and to strengthen
and define its identity and name recognition.
Consistency in the use of these symbols is critical
to UVM’s identity and reputation.
Improper or
unauthorized use
is prohibited and
could violate
state and/or
federal law.
34freedom of expression
Example
• Setting up a Facebook
account to look like it is
officially sanctioned by the
University when, in fact, it is
not.

35. page | 35
campus speakers, political
activity & solicitation
If you are inviting a speaker, regardless of whether it is a paid
engagement or not, you need to follow the procedures outlined in
University policy.
As a tax-exempt organization, UVM has to comply with IRS regulations related to political activities.
The University cannot participate in a political campaign. Similarly, personnel including officials,
administrators, faculty and staff, in their official capacity, cannot make statements related to a
campaign in any manner. Contact University Relations at (802) 656-5690 with questions.
We have a need to protect public safety and to enforce rules and regulations related to the use of campus
grounds and facilities. Anyone wishing to use University space or facilities must contact the University
Event Services at (802) 656-5665.
35freedom of expression
campus
speakers
political
activity
solicitation

36. page | 36
conclusion
“Continuous improvement is
better than delayed perfection.”
-Mark Twain, Writer,
Entrepreneur, Publisher and
Lecturer (1835 – 1910)

37. page | 37
resources(click on any link to access the full document)
37
While the Office of Compliance Services oversees the University’s compliance
program, there are other offices and individuals that can provide guidance when
faced with a difficult decision or situation.
• Faculty Senate
• Human Resources Services
• Office of Audit Services
• Office of General Counsel
• Office of the Vice President of Executive Operations
In addition to these resources, the University also offers these resources depending on the issue or your needs. Click on any resource for
more information.
conclusion
• Affirmative Action & Equal Opportunity (AAEO)
• Disability Certification and Support
• Office of International Education
• Risk Management & Safety
• Sponsored Project Administration (SPA)
Office of the Vice President for Human Resources, Diversity and
Multicultural Affairs
Diversity and Equity Unit
Student Financial Services
University Financial Services

38. page | 38
policy references, related
documents & links
38conclusion
Your Code of Conduct and Ethical
Standards references several
University policies and University
Operating Procedures, or UOPs, that
provide more information related to
these risk areas. In addition, the Code
lists out related documents and links
that provide additional guidance.
Personnel should refer to the Code for
a complete list of policies, procedures,
documents and links.

39. page | 39
contacts
39
CONTACT INFORMATION FOR CLARIFICATION ON THE CODE
Tessa Lucey, Director of Compliance Services, Office of Audit & Compliance Services
(801) 656-0847
Tessa.Lucey@uvm.edu
Compliance@uvm.edu
Billings Library, B159
48 University Place, Burlington, VT 05405
ETHICS AND COMPLIANCE
REPORTING & HELPLINE
877-310-0413
OR
click here:
conclusion

40. page | 40
appendix (click on any link for additional information)
40conclusion
HEALTH, SAFETY & CAMPUS ENVIRONMENT
CREATING A RESPECTFUL CAMPUS ENVIRONMENT
• Our Common Ground
• Diversity Statement
• Equal Employment Opportunity/Affirmative Action Policy Statement
• Equal Opportunity in Educational Programs and Activities and Non-Harassment
• Sexual Misconduct and Harassment
• Disability Accommodations for Employees and Applicants for Employment
• Amorous Relationships with Students
• Amorous Relationships – Department of Athletics
CREATING A SAFE AND HEALTHY CAMPUS – PERSONAL SAFETY
• Alcohol Policy – Faculty and Staff
• Campus Safety and Security: Clery Act
• Campus Security Authorities (CSA) – Designation of and Reporting By

41. page | 41
41conclusion
HEALTH, SAFETY & CAMPUS ENVIRONMENT
CREATING A SAFE AND HEALTHY CAMPUS – PERSONAL SAFETY (CONTINUED)
• Drug Free Workplace
• Personal Safety and Security
• Sexual Harassment and Misconduct
• Weapons and Explosives
• Minors in the Lab
• Protection of Minors
• Minors; Reporting of Abuse or Neglect of and Crimes
CREATING A SAFE AND HEALTHY CAMPUS – ENVIRONMENTAL SAFETY
• Emergency Management
• Fire Safety
• Laboratory Health and Safety
appendix (click on any link for additional information)

42. page | 42
42conclusion
FISCAL COMPLIANCE & ASSET MANAGEMENT
PRIVACY AND SECURITY OF CONFIDENTIAL INFORMATION
• Privacy
• FERPA Rights Disclosure
• Data Breach Notification Policy
• Records and Document Requests
• Records Retention
• Information Security
• Computer, Communication, and Network Technology Acceptable Use
CONFLICTS OF INTEREST AND CONFLICTS OF COMMITTMENT
• Conflict of Interest and Commitment
• Financial Conflict of Interest in Sponsored Research
appendix (click on any link for additional information)

43. page | 43
43conclusion
FISCAL COMPLIANCE & ASSET MANAGEMENT
PROTECTING UNIVERSITY ASSETS AND APPROPRIATE USE OF RESOURCES
• Procurement or Lease of Goods and Services and Contract Approval and Signatory Authority for Procurement or Lease
of Goods and Services
• Computer, Communication, and Network Technology Acceptable Use
• Business Meals, Hospitality, and Amenity
• Travel
• Contract Approval and Signatory Authority
• Facilities and Grounds Use
ACCURACY IN RECORDKEEPING
• Records Retention
• Effort Management and Reporting on Sponsored Agreements
appendix (click on any link for additional information)

44. page | 44
44conclusion
FISCAL COMPLIANCE & ASSET MANAGEMENT
ACCURACY IN RECORDKEEPING (CONTINUED)
• Travel
• Business Meal, Hospitality and Amenity
• Export Controls
• Movable Equipment
• I-9
RELATIONSHIPS WITH UNIVERSITY VENDORS AND OTHER THIRD
PARTIES IN BUSINESS TRANSACTIONS
• Affiliated Organizations
• Procurement or Lease of Goods and Services and Contract Approval and Signatory Authority for Procurement or Lease of
Goods and Services
appendix (click on any link for additional information)

45. page | 45
45conclusion
RESEARCH
REGULATION AND RISK
• Copyright
• Cost Transfers Involving Sponsored Agreements
• Effort Management and Reporting on Sponsored Agreements
• Establishment of Advance Accounts for Sponsored Agreements
• Export Controls
• Intellectual Property
• Issuing and Monitoring Subawards on Sponsored Agreements
• Misconduct in Research and Other Scholarly Activities
• Moveable Equipment
• Residual Balances on Sponsored Agreements
• Use of University Research Facilities and Equipment by External Users
appendix (click on any link for additional information)

46. page | 46
46conclusion
FREEDOM OF EXPRESSION
MISSION AND EXPECTATIONS
• Campus Speakers
• Copyright
• Political Activities: Tax Exempt Organization Restrictions
• Solicitation
• Trademarks
• University Name, Symbols, Letterhead and Other Proprietary Indicia of Affiliation
• University Sponsored Social Media
appendix (click on any link for additional information)

47. page | 47
related documents & more links
(click on any link for additional information)
47
Employee Handbooks and Collective Bargaining Agreements
Statement of Commitment and Expectations In The Workplace
UVM Institutional Policy Website
HelpLine FAQ’s
Why Diversity Statement
Effort Management Tutorial
conclusion

48. page | 48
the
end
thank you