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Code of Ethical Conduct and Conflict of Interest

 Scope
All financial and administrative policies involving community members across campus, volunteers, are within the scope of this policy. If there is variance between departmental expectations and the common approach described through college policy, the college will look to the campus community, volunteers to support the spirit and the objectives of college policy.
Policy
The President of the College delegates administration of the college’s Code of Ethical Conduct and Conflict of Interest
Code of Ethical Conduct Compliance with Laws and Regulations
In conducting our affairs, every campus community member is expected to comply with all federal, state, and local laws, rules and regulations. One of the duties of campus community members is to be aware of these laws, rules and regulations to the extent possible. It is EVC’s sincere hope and expectation that each Responsible Person’s own integrity and ethical behavior will result in full compliance with laws, regulations and the Code of Ethical Conduct. However, if any campus community member is found to have intentionally violated this Code, that person may be subject to discipline, including oral or written warning, suspension with or without pay, or dismissal.
EVCs Assets
EVC’s assets must be safeguarded and used only for proper purposes. This obligation applies to all tangible property of EVC (for example, physical facilities, office equipment, furniture and supplies, AND TRUCKS) as well as to all intangible property of EVC (for example, computer software, trademarks, and copyrighted materials). EVC’s confidential and proprietary information must also be safeguarded, as discussed in the section below titled “Confidential Information.” Accounting For and Recording Transactions
EVC’s books, records, accounts, and financial statements must be maintained to accurately depict EVC’s transactions. They must also conform to applicable legal and accounting standards. Each campus community member should ensure that every business record prepared by him or her, or under his or her direction, is accurate, complete and reliable. Campus community members must not coerce, manipulate, mislead or improperly influence EVC’s auditors in the performance of an audit or review of EVC’s financial statements.
Confidential Information
“Confidential information” refers to information that is not available to the public (or that someone would normally expect to be non-public). For example, confidential information includes: • information marked as “Confidential,” or with a similar marking; • information relating to hiring decisions, and to current, former and prospective employees; • student records; • information relating to current, former and prospective trustees and other volunteers that has not been made public; • financial reports and data that have not been made public (including social security numbers and credit card numbers and information); and • donor lists and all personal information about donors. Campus community members must use reasonable care to safeguard confidential information. This means campus community members will: • not leave confidential information unattended or in public view; • not access confidential information unless the information is required in order to conduct EVC affairs; • not remove confidential information from EVC’s premises or make copies of any material containing confidential information, except as required to conduct EVC affairs; • never use or disclose any of EVC confidential information for personal gain or profit, or to the advantage of any “related person” to a Responsible Individual (as that term is defined in EVC’s Code of Ethical Conduct and Conflict of Interest); and
Gifts and Gratuities
The giving and receiving of gifts, offers of outside employment, gratuities, or other advantageous arrangements is an area that raises special concerns with regard to conflicts of interest, and is regulated by federal and state law. Other than modest gifts ($100 or less in value), campus community members may not give or receive gifts from persons doing business with or seeking grants or other financial commitments from EVC.
Political Involvement
EVC is permitted to host certain political activities and political campaign events, but only done so in a nonpartisan manner, for an educational purpose, and with “equal access” to all other candidates and issues related to the event or activity hosted on campus. While the guidelines on political involvement do not apply to campus community members acting in their personal capacities, care must be taken so that no individual activity is attributed to EVC. Therefore, campus community members will not:
      • conduct prohibited partisan political activities on EVC’s premises;
      • use EVC’s facilities, equipment, supplies, personnel, or other resources to conduct or support prohibited partisan political activities; or
      • associate EVC with any partisan political activity in such a manner as might indicate EVC’s partisan participation or intervention in a political campaign.
Reporting Concerns
The college encourages all faculty, staff, students, and volunteers to report suspected or actual wrongful conduct (including but not limited to EVC’s assets, conflicts of interest, confidential, and respectful behavior) to their direct supervisor. The college has an obligation to accommodate and make provisions for those who lack the comfort or the confidence to share their concerns directly with their supervisors. Therefore, anyone aware of a violation of the college’s Code of Ethical Conduct and or Conflicts of Interest, but who is uncomfortable reporting to their supervisor, or who wants to remain anonymous, is expected to promptly report the matter to the college’s Superviser for confidential handling. Anyone knowingly or recklessly reporting false information will be subject to disciplinary action up to and including termination.
No Retaliation
Retaliation is an act of punishment, reprisal or revenge that is taken against a person because they complained of behavior, or assisted in a complaint under this Policy, or because they participated in an investigation under this Policy. Retaliation can take many forms in the workplace, as described below, but essentially, retaliation can be any action that is taken against a person that would deter a reasonable person from coming forward to complain of misbehavior under this Policy. Retaliation is a serious problem and a fear of retaliation prevents issues from surfacing, keeps people from raising problems and enables a culture of harassment to fester. East Valley College recognizes the seriousness of Retaliation and is committed to responding to and addressing Retaliation concerns proactively and reactively upon receipt of a complaint of Retaliation. East Valley College prohibits Retaliation against any person for having complained about violations of this Policy, assisting in such a complaint or participating in an investigation into such a complaint, whether the complaint raises a failure to meet the Respectful Workplace Expectations or raises a violation of the Discriminatory or Sexual Harassment provisions, or for having assisted or participated in an investigation of alleged violations. Retaliation is further defined under Definitions.
Conflicts of Interest
A Responsible Individual and EVC should consider whether a relationship or situation creates the appearance of a conflict of interest, as well as an actual conflict of interest. Conflicts of interest commonly arise through direct or indirect significant financial interests that a Responsible Individual or a Related Party, may have in companies or organizations that do business with EVC. A conflict of interest may also arise from a Responsible Individual or Related Party having a membership on a board of directors or board of trustees – even an advisory board, a non-paid board, or a non-profit or charitable board. Certain types of conflicts are unavoidable and immaterial in their impact. All conflicts or potential conflicts will be reviewed as to whether they are improper or create the appearance of impropriety. Disclosure and a reasoned review of each situation in light of all circumstances will ensure transparency as well as fairness for the interests of EVC and the Responsible Individual. Conclusion Each Responsible Individual is entrusted with safeguarding and promoting EVC’s educational mission through ethical and principled leadership and action. If there are concerns about any action that might violate EVC’s Code of Ethical Conduct. Procedures and Reporting Options Conflicts of Interest Procedures (1) New Hires The college will ensure that the college has a process to support sharing the Code of Ethical Conduct and Conflict of Interest with new hires and obtaining signed acknowledgments from them. (2) Review of Potential Conflicts of Interest The college’s administrator disclosures to determine if a conflict exists. If so, they will make recommendations that allow the college to monitor, minimize, or eliminate the conflict.
Reporting Options (applies to Conflicts of Interest and Code of Ethical Conduct)
The college encourages all faculty, staff, students, and volunteers to report suspected or actual wrongful conduct (including but not limited to EVC’s assets, conflicts of interest, confidential, and respectful behavior) to their direct supervisor. Anyone aware of a violation of the college’s Code of Ethical Conduct and or Conflicts of Interest, but who is uncomfortable reporting to their supervisor If an investigation is required, it could be conducted internally, using college expertise, or be done by a third-party expert.