Topics

2. Topics • University Guide to the State Code of Ethics • Campus Security • Policy Against Discrimination, Harassment and Inappropriate Romantic Relationships • Working with Industry • Grant Management

3. University Guide to the State Code of Ethics • Gifts • Outside Employment • Financial Benefit/Use of Office • Contracts with the State • Appearance Fees • Political Activity • Post Employment

4. University Guide to the State Code of Ethics Employment and Contracting for Service of Relatives Policy • No employee may be the direct supervisor of or take any action which would affect the financial interests of one’s relative. • relative is defined as: spouse, child, step-child, child’s spouse, parent, brother, sister, brother-in-law, sister-in-law, dependent relative or a relative domiciled in the employee’s household. • Under no circumstances will the University approve the employment of dependent children or step-children as student employees under direct or indirect supervisory relationships.

5. University Guide to the State Code of Ethics Responsibilities as a State Employee • As a state employee, our first priority is to our state position • May not use your position for personal financial gain • Includes using resources for outside activities • Must separate our state responsibilities from our private endeavors • Compliance is the responsibility of the employee, not the University.

6. University Guide to the State Code of Ethics Resources • Compliance Office – www.audit.uconn.edu • Call or email • Compliance Courier newsletter • Daily Digest

7. Campus Security

8. The Jeanne Clery Disclosure of Campus Security Policy & Crime Statistics Act • The Clery Act, first enacted in 1990 and amended in 1998, requires higher education institutions to publish safety policies and report crime statistics to current & prospective students & employees • To ensure that students know about dangers on their campuses, the Clery Act requires institutions to gather and publish data from additional Campus Security Authorities

9. Who is a Campus Security Authority (CSA)? • University Police Department • Individuals with Campus Security Responsibilities • Individuals Designated by the Campus • Officials with significant responsibility for student and campus activities who are likely to receive complaints from a victim of crime

10. Examples of CSAs: • Dean of Students • Provost and Staff • Representatives of Housing and Resident Life • Student Judicial Programs / Other Discipline Officials • Directors or Managers of Student Service Centers • Officials who oversee extracurricular activities • Director of Athletics, Coaches, Trainers, Staff • Student Health Directors • Faculty Advisors and Advisors to Student Groups

11. Exceptions • You are a licensed mental health counselor or a pastoral counselor (employed by a religious organization to provide confidential counseling) AND • You are working within the scope of your license or religious assignment • University Health Services Physicians and Nursing Staff working within the scope of their medical responsibilities

12. You do not need to report crimes as a CSA if: • A person tells you about a crime that occurred before he/she came to the University OR • While he/she was away from campus and not involved in a University Sponsored activity—e.g., at home, on spring break etc.

13. What CSAs Should Report • When the crime occurred • When was it reported to you • Location where the incident occurred • As many facts as possible

14. Clery Geography: Location You must report if it occurred • On campus • On campus, in residence halls • On public property adjacent to campus • On non-campus property owned or controlled by the University or a recognized student organization

15. What are Clery Crimes? • Criminal homicide • Sex offenses—forcible & non-forcible • Intimate partner violence & stalking • Robbery • Aggravated assault • Burglary • Motor vehicle theft • Arson • Arrests & disciplinary referrals for violations of liquor, drug, & weapon laws • Hate crimes

16. The Clery Incident Report Form Serves as a Description of the incident or crime • Specific questions will help police assign the crime to the correct category • Get as accurate and complete a description of what happened as possible • If not sure, report

18. Timely Reporting is Required The Clery Act requires an alert to the campus that is timely and will prevent similar crimes. It is based on: • The nature of the crime • The continuing danger to the community • The possible risk of compromising law enforcement efforts

19. Resources Provide the victim with information on: • Reporting to campus police (victims are encouraged to report to the police) • Campus programs for assisting victims of sexual and other assault • Procedures for seeking medical assistance

20. Best Options as a CSA • Call the Police • Record the incident that may be a crime using the Clery form, if it is NOT an emergency Resources Clery Coordinator Phone: 860-486-5181 www.clery.uconn.edu

21. Title IX • Federal law that prohibits discrimination based on the sex (gender) of employees and students of educational institutions that receive federal financial assistance • The University has designated Elizabeth Conklin as the University’s Title IX Coordinator and charged her with ensuring that reports of sex discrimination, sexual harassment and sexual violence are addressed by the University Title IX CoordinatorElizabeth ConklinWood Hall, first floorPhone: (860) 486-2943 Email: elizabeth.conklin@uconn.edu

22. Sexual Violence Awareness website • Identifies campus and off-campus resources for victims, steps that can be taken to ensure safe educational and living environments, as well as options for reporting •  Provides awareness, resources, and education for students, employees, parents, and visitors concerning sexual violence • what it is • what to do if it happens • where to go for support • Drop-down menus provide specific information including definitions, FAQs, and resources

24. Safety in the Workplace Resources

25. Policy Against Discrimination, Harassment, and Inappropriate Romantic Relationships

26. A single, comprehensive discrimination, and harassment policy approved by the Board of Trustees on August 7, 2013 • Articulates University values and community conduct expectations – the University will not tolerate discrimination or discriminatory harassment in the learning or working environments. • Adds language prohibiting certain romantic relationshipswhere power disparities are present • “Romantic” includes intimate, sexual, and/or any other type of amorous encounter or relationship, whether casual or serious, short-term or long-term. Policy Against Discrimination, Harassment, and Inappropriate Romantic Relationships

27. Faculty/Staff Relationships with Undergraduate students • All faculty and staff are prohibited from entering into a romantic relationship with any undergraduate student. Faculty/Staff Relationships with Graduate students • All faculty and staff are prohibited from entering into a romantic relationship with a graduate student actually under that individual’s authority. • “Authority” includes teaching, formal mentoring or advising, supervision of research, employment, grading, or disciplinary action. Graduate Student Relationships with other Students • Any Romantic relationship between a graduate student and a student over whom they have authority is prohibited. Romantic Relationships – Instructional Context

28. Employment Context • All faculty and staff are prohibited from pursuing or engaging in romantic relationships with employees whom they are currently supervising. Existing Relationships • If a relationship existed prior to joining the University, that relationship must be disclosed to ODE and/or OFSLR by the employee in a position of authority prior to accepting a supervisory role. Romantic Relationships – Employment Context& Existing Relationships

29. Mandatory Reporting • Deans, Directors, Department Heads, and Supervisors are obligated to report any discrimination, harassment or inappropriate Romantic relationship to ODE and/or OFSLR as soon as it becomes known to them. • Failure to report any known incidents is a policy violation as serious as the original discriminatory act. • Complaints about student misconduct are addressed through Community Standards. ‘Student’ includes student-employees and graduate students, even when acting as Teaching Assistants or Research Assistants. Manager Reporting Obligations

30. Intended to assist employees and their managers with meeting the requirements of the Policy. • Form is available online: www.policy.uconn.edu • Separate form for Graduate Students and Postdoctoral Scholars Romantic Relationship Disclosure Form

31. Resources Office of Diversity & Equity Telephone: (860) 486-2943 Official Website: http://ode.uconn.edu/

32. Working with Industry

33. Working with Industry • The University encourages work with industry partners to meet its research and business goals • All arrangements with industry partners, including sponsored research, collaborations, consortiums and new centers must be reviewed and approved by the appropriate UConn Offices • There are several University policies that faculty and staff should be familiar with before engaging with industry

34. Faculty Consultinghttp://consulting.uconn.edu/ • Members of the faculty and members of the faculty bargaining unit may participate in consulting activities while complying with the State of Connecticut Code of Ethics, the University of Connecticut Ethics Statement, the University's Code of Conduct and the University's Laws and Bylaws. • Faculty should always ensure that their University responsibilities are fulfilled prior to requesting or fulfilling consulting opportunities. • Consulting has three major components: • Due to a faculty member’s expertise; • Not related to, or due to, a faculty member’s state employment; • The faculty member will be compensated for the activity.

35. Faculty Consulting • Faculty cannot compete with the University for work it has or is planning to do by teaching a course at another institution for compensation. Faculty members may request permission to teach elsewhere as long as the assignment is determined to be beneficial to the interest of the University • Use of state resources while consulting is permissible in very specific, limited circumstances • http://consulting.uconn.edu/policies.html

36. Faculty Consulting • When describing the contracting entity, the online consulting form asks the following as it relates to working with industry: • Are you a member of the contracting entity's board? • Does a member of your family (spouse, child, parent) or you have at least 5% ownership interest in the contracting entity? • Is the contracting entity a University start-up company or a faculty-affiliated company (i.e. [1] it has licensed University Intellectual Property (UIP) in which you are an inventor, and/or [2] a founder, owner, or scientific advisor)?

37. Use of Students in Outside Employment • Provides guidance on the employment of students by faculty and staff for work external to the University and ensure compliance with the State Code of Ethics. • Potential conflicts may occur when a University employee hires a student in any non-University supported activity. • Employees who choose to employ students in any non-University activity must disclose the intent to do so in writing, prior to employing the student, and this written disclosure should be made to the Department Head/Dean or appropriate University official.

38. Important Points for Working with Industry • UConn is dedicated to ensuring that all University activities are managed in accordance with University policies, ethical guidelines, and transparency. • UConn supports and encourages relationships between members of the University community and outside organizations to advance its academic mission. • Some situations may give rise to actual or perceived conflicts of interest and/or conflicts of commitment. • External entities (such as Federal and State governments) have expectations of professional and acceptable behavior related to conflicts of interest. Such entities exercise their rights to require compliance to standards and rules accordingly.

39. Definitions Conflict of Interest: A conflict of interest occurs when there is a divergence between an employee’s private interests and that employee’s professional obligations to the University such that a neutral observer might reasonably question whether the employee’s professional actions or decisions may be influenced by considerations of personal gain or the personal gain of a family member or a business with which they, or a family member, are associated, including future personal gain. Conflict of Commitment: A conflict of commitment can exist when an employee of the University has a relationship that requires a commitment of time or effort to non-University activities which interferes with the employee’s ability to meet his or her professional obligations to the University. A conflict of commitment may also exist in if an employee directly or indirectly engages in competition with the State for work or compensation that the State would normally choose to perform.

40. Preventing Conflicts of Interest The University has identified the key principles listed below to guide the conduct of its community in avoiding conflicts of interest: • Avoid actual conflicts of interest and commitment and disclose any situation in which there might be a perception that a real conflict of interest and/or commitment exists. • Monitor potential conflicts so that guidance from appropriate campus resources can be sought before an actual conflict occurs. • Follow local, state and Federal laws, nongovernmental (e.g. accrediting organizations) regulations, and University policies, procedures, and guidelines.

41. Office of the Vice President for Research • UConn’s Office of the Vice President for Research (OVPR) provides the following services related to University and industry contacts: • Technology commercialization, protection and licensing of intellectual property; • Industry-supported research collaborations and sponsored research; • Outreach to industry to build awareness of UConn as a resource; • Industry feedback on UConn technologies, research, and initiatives; • Entrepreneurial and small business assistance.

42. Grant Management

43. Federal Acquisition Regulations (FARs) Effectively Managing your Grants and Contracts • Regulations & Policies • Period • Approval of • Sub-awards • Deliverables • Intellectual • Property • Signature • Authority • Contracting • Procedures • Code of Ethics • EDGARs • PHS Grants • Policy • OMB Circulars • A-21,110,133 • Export Control • Regulations

44. OMB Circulars—A-21 • Establishes principles that colleges and universities must use to determine costs applicable to grants, contracts, and other federal agreements. • Primary source for determining the allowability of costs. • Describes what costs can be included in the F&A rate. • Specifically addresses 54 selected items of cost and classifies them as allowable or unallowable (Section J).

45. OMB Circulars—A-110 • Sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals and other non-profit organizations. • Establishes instructions and forms to be used in applying for federal assistance. • Prescribes standards for financial and program management of sponsored research awards

46. OMB Circulars—A-133 • Sets forth standards for obtaining consistency and uniformity among Federal agencies for the audits of States, local governments, and non-profit organizations expending Federal awards. • Describes federal and recipient audit responsibilities. • Describes recipient’s responsibilities for subrecipients. • Requires annual audits.

47. Agency Specific Regulations -Examples • NIH Grants Policy Statement http://grants1.nih.gov/grants/policy/nihgps_2003/index.htm • NSF Grant Policy Manual http://www.nsf.gov/publications/pub_summ.jsp?ods_key=gpm • Department of Defense Grant and Agreement Regulations http://www.dtic.mil/whs/directives/corres/html/32106r.htm • Education Department Grants and Administrative Regulations http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

48. OVPR Policies—Minimum Faculty Effort • Federal guidelines stipulate that most Federally-funded research programs should include some level of committed faculty (or senior researcher's) effort, regardless of whether or not they are paid from the grant. • All proposals must include a minimum of 1% commitment by the PI to the project. Faculty who do not propose a minimum level of effort must provide the reason(s) at the time the proposal is submitted to OSP.

49. OVPR Policies—Financial Conflict of Interest in Research What is a Financial Conflict of Interest? Financial conflicts of interest in research may occur when outside significant financial interests (SFI) compromise, or have the appearance of compromising, the professional judgment of an investigator when designing, conducting, or reporting research. How has the policy changed? UConn's revised FCOI policy was effective on August 24, 2012 and corresponds with the 2011 Public Health Service revised financial conflict of interest (FCOI) regulations (42 CFR 50). These regulations apply to any institution receiving funds from a PHS entity. What are my responsibilities? All UConn Investigators must: • Submit a Significant Financial Interest Review Form when submitting a new proposal, when there are changes in an SFI, and when they are a new investigator on an ongoing project. When there are human subjects, the investigator must disclose SFIs to the Institutional Review Board with every submission of protocols. • Complete a Supplemental Financial Interest Disclosure Form when an SFI exists. • Understand UConn's policy on financial conflicts of interest and know the definition of SFI and how it applies to them.

50. UConn Policies—Review and Approval of Proposals • All proposal submissions seeking external support for research and other sponsored projects must be submitted to Sponsored Programs Services for review and approval prior to submission to the sponsor.