Code of Ethics for Financial and/or Fiduciary Employees

Wilkes University is dedicated to the highest ethical and professional standards of conduct and complies with all applicable laws and regulations related to all University affairs.  In order to maintain this dedication, all Wilkes University employees are required to maintain the same ethical standards and principles when conducting University business in a manner that excludes considerations of personal advantage or gain.

Some essential principles of responsible and professional behavior for all Wilkes University employees include (but are not limited to), honesty, trustworthiness, integrity, dignity, respect and fairness in dealing with others,  a sense of responsibility toward others and loyalty to the ethical principles promoted by the University through our mission, vision and values.

Financial employees with direct responsibility for any function related to the collection, processing, recording, reviewing or management of business transactions or financial reports, statements or disclosures have ethical responsibilities in addition to the Wilkes University Code of Ethics due to their potential impact to the University.  These employees normally work in the financial organizations which have direct responsibility for the University’s financial transactions and functions.  The financial organizations include, but are not limited to the: Office of the Vice President, Finance and General Counsel, Controller’s Office, Purchasing and Contract Services Department, Development and Alumni Affairs, Human Resources and Grants Support.

Senior leadership in all financial organizations serve as role models for their employees and must demonstrate and promote the highest standards of ethical conduct at all times.  They are responsible for protecting, balancing and preserving the interests and assets of the University and creating and enforcing policies that:

  • Encourage and reward professional integrity in all aspects of the University’s financial organization
  • Prohibit and eliminate conflicts between actions by any member of the financial organization that serve the University’s best interest versus actions taken for potential material personal gain (Conflict of Interest and Financial Disclosure Policy)
  • Provide a mechanism to inform University Officials of practices which deviate from established University policies and procedures (Confidential Reporting Policy)

Senior leadership must also demonstrate their personal support for the policies and procedures via regular communication to reinforce ethical standards and expectations.

Financial Records and Reports
Senior financial employees establish and manage transaction and reporting systems and procedures to ensure that:

  • Business transactions are properly authorized and recorded on the University’s accounting systems/records in a complete and accurate manner in accordance with Generally Accepted Accounting Principles (GAAP) and University policies.
  • The retention or proper disposal of University records comply with all applicable legal and regulatory requirements and University policies.
  • Periodic financial communications and reports provide the highest degree of clarity of content and meaning to ensure that readers and users can quickly and accurately determine their significance and consequence.

Compliance with Applicable Laws, Rules and Regulations
Senior financial employees ensure that all University business transactions comply with all laws, rules and regulations by establishing and maintaining mechanisms to:

  • Educate financial employees about any federal, state or local law, statute, regulation or administrative procedures related to the operation of the finance organization to ensure compliance with laws and regulations related to their duties.
  • Monitor the finance organization’s compliance with any applicable federal, state or local law, statute, regulation or administrative rule.
  • Efficiently and effectively identify, report and correct any potential deviations from applicable federal, state or local law, statute or regulation.

Data Collection and Management
The falsification, fabrication and/or misrepresentation of any financial data are unethical and prohibited.

Fiscal Responsibilities
Employees of the financial organization are obligated to provide up-to-date records of financial transactions for each department to monitor their progress. Those responsible for budgets and grants must monitor records of expenditures for compliance with University policies and procedures.  These records must be available for review by University employees. All funds provided for research, grants or other restrictions must be spent consistent with the funding documents and in compliance with the guidelines on allowable costs.  All files are the property of the University.

Compliance
Senior financial employees play a vital role in articulating and demonstrating an ethical culture for the University and must ensure that the highest standards of ethical practice prevail.  The senior financial employees report all code procedures, including actions taken regarding communication, compliance and/or violations to the Audit Committee.

All financial organization employees must sign an acknowledgement of the code and a commitment to the application of the standards and principals in their daily job responsibilities on an annual basis.

All financial organization employees must comply with the provisions of this code and the ethical standards of professional conduct and integrity set forth by the code. In order to comply with this policy, all financial organization employees are required to understand and comply with all related laws and University policies/procedures.

Reporting Suspected Violations or Concerns
The University is focused on teaching the appropriate compliance standards of ethical conduct to all financial organization employees. Financial organization employees have a duty to adhere to the standards set forth in the code, to recognize violations and to enforce the standards. Any employee that becomes aware of a code violation should first, whenever possible report it to a supervisor, department director or Human Resources immediately.  In addition, all employees are obligated to report any activity that appears to violate laws, rules, regulations, policies or procedures.   Employees with any questions related to ethics or compliance should consult their supervisor, department director on Human Resources. The University recognizes that employees may not always feel comfortable reporting alleged violations of this policy in person.  The University has established a confidential reporting mechanism to ensure all employees have the opportunity to make a report without revealing their identity (see Confidential Reporting Mechanism).

Failure to make a report may result in disciplinary action up to and including termination of employment.  Disciplinary actions for code violations or retaliation against those reporting possible violation will be determined on a case-by-case basis and may include termination of employment.

INVESTIGATION
The Human Resources Department, in conjunction with the appropriate division head(s) and Legal Counsel (when applicable), will investigate all claims of conduct or behavior alleged to be harassment and will take appropriate action(s) at the conclusion of the investigation.  The Human Resources Department will maintain all investigatory records.   If Human Resources employees are implicated in the allegation, the President will name another University official to conduct the investigation and maintain records.

Disciplinary action for proven violations of the code, or for retaliation against anyone reporting possible violations, will be determined on a case-by-case basis and may include termination of employment.

This policy is subject to the direct oversight of the Audit Committee, in carrying out its responsibilities to receive regular reports on compliance from management.

Issued:  10/1/2007       Revised: 12/2012