Policy 10.03: Code of Conduct and Professionalism

I. Policy

College-Wide Integrity and Ethical Standards

The successful business operation and reputation of Quincy College ("The College") is built upon the principals of fair dealing and ethical conduct of its employees and is one of its most valuable assets. The College's reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. The continued success of the College is dependent upon students and community trust and the College is dedicated to preserving that trust. Employees owe a duty to the College, it's students, and constituents to act in a way that will merit their continued trust and confidence. It is the policy of Quincy college to comply with all applicable laws and regulations and the College expects all its employees to conduct business in a manner consistent with College policies and in accordance with the letter, spirit and intent of all relevant laws and to refrain from any illegal, dishonest of unethical conduct.

All Employees and others that provide services for compensation for the College ("Employees" and "Agents"), therefore, shall conduct all work-related activities in keeping with the highest ethical standards. Employees and Agents are also expected to conduct their personal affairs in a manner which will not reflect discredit on the College, and must avoid situations that might lead to a conflict, or even the appearance of a conflict, between the Employee's or Agent's interests and his or her responsibilities to Quincy College.

Quincy College depends upon each and every Employee's or Agent's observance of ethical standards and consistent use of good judgment, fairness and personal integrity. We expect Employees and Agents to be courteous, discreet, dependable and principled in dealings with students, co-workers, management and others. All Employees or Agents are required to adhere to the ethical standards published by the professional organizations of their discipline with special emphasis on those policies that pertain to unacceptable behavior with students or patients in the clinical educational settings.

Dual relationships (a personal and work-related relationship) of any type between service providers and customers are complex and should be reviewed with supervisors to determine the appropriateness of maintaining that relationship. Such professional behavior is very important in our business, and we take this expectation very seriously, as should Employees and Agents.

II. Procedures

In general, the use of good judgment, based on high ethical principles, will guide the employees with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with the immediate supervisor and, if necessary, with Human Resources for advice and consultation.

Conflict of Interest:

The Conflict of Interest Law, Massachusetts General Laws, Chapter 268A, is designed to prevent situations in which an individual's private interests conflict with his or her responsibilities as a public employee. The law has provisions which prohibit the acceptance of gifts, which prohibit the involvement of public employees in state contracts and related matters in which they may have a financial interest, and which restrict the types of secondary state employment certain types of employees may accept. The law has numerous other provisions of a similar nature.

Compliance with the law is the individual responsibility of the employee. Violation of the law can result in fines as well as criminal penalties. Employees who have specific questions about the Conflict of Interest Law should contact the Human Resources Department at 617- 984-1611, the Ethics Commission at 617-727-0060 or visit their website at www.state.ma.us/ethics.

Employees and Agents shall disclose in writing to the President any person to whom they are closely related or any organization with which they are affiliated who or which presently transacts business with the College or a related entity or might reasonably be expected to do so in the future. Each disclosure shall be updated and resubmitted to the President on an annual basis. In addition, an Employee or Agent is required (as a matter of policy) at any time during which such Employee or Agent becomes aware of an actual or potential conflict of interest, to immediately disclose such conflict to the President. The disclosure shall identify in writing the nature of the conflict and all the material facts and circumstances surrounding the conflict, which would be necessary for the President to make an informed decision with respect to the transaction. The disclosure of an employee is not limited to his or her own conflicts, but shall include any conflict of any other employee or agent which is known to an employee or agent.

Upon the disclosure of an actual or potential conflict of interest of an employee, the President may take action despite the conflict if all of the following conditions are met:

The employee with the conflict provides the material information to the President;
A majority of the disinterested governors, even if less than a quorum, takes action with respect to the conflict and with all material information;
If the common interest is disclosed and the contract or transaction is fair and reasonable to the corporation.

Violations of the Conflict of Interest:

If the President has reason to believe that an interested party has failed to disclose an actual or potential conflict of interest, it shall inform the person of the basis for such belief and allow the person an opportunity to explain the alleged failure to disclose.

If, after hearing the response of the employee and making such further investigation as may be warranted in the circumstances, the President and/or Board of Governors determines that the employee has in fact failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

Compliance with this policy of business ethics and conduct is the responsibility of every College employee. Disregarding or failing to comply with this standard of business ethics and conduct may result in disciplinary action, up to and including possible termination of employment.

Gifts or Favors:

Employees or Agents must not use their College positions for personal gain or advantage or give that appearance. Employees, Agents and their families must not accept gifts or favors with a value of more than fifty dollars ($50.00) from students (or their family members), suppliers or vendors. To accept gifts or favors with a value of more than fifty ($50.00) is a violation of Quincy College policy and may result in disciplinary action up to and including termination of employment.

Improper Payments:

No Employee or Agent may make or receive any payments or authorize any expenditure in connection with the College business that represents bribes, kickbacks or payoffs; are falsified, deliberately unrecorded or undocumented in College's records when required; violates applicable laws or regulation. No Employee or Agent shall exert influence on another Employee or Agent to provide services to or purchase goods from another Employee or Agent.

Outside Activities:

Outside employment or participation in the affairs or another businesses or organizations may create conflicts of interest and interfere with the Employee's or Agent's primary responsibilities to College. An Employee or Agent may hold a job with another organization or another department within the College as long as he or she satisfactorily performs his or her job responsibilities with his or her primary function at the College. All Employee's and Agent's performance will be reviewed by the standards set forth in the appropriate current collective bargaining agreement and/or the College policy and will be subject to the College's scheduling demands, regardless of any existing outside work requirements.

Personal interests that conflict or appear to conflict with the interest of the College shall be avoided. While the existence of such actual and potential conflicts of interest can be determined only upon the review of the particular circumstances of a given situation, and it is impossible to list every circumstance that might present a conflict, the following examples serve to illustrate the type of situation that should be avoided:

Ownership of a substantial financial interest or management controlled by an Employee or Agent or any member of his or her family for any outside concern that does business with, or is a competitor of Quincy College, other than ownership of securities of a publicly-owned corporation traded on the open market.
Representation of Quincy College by an Employee or Agent in any transaction in which the Employee or Agent or any member of his or her family has a substantial interest.

If the College determines that an Employee's or Agent's outside work interferes with performance or the ability to meet the requirements of the College as they are modified from time to time, the Employee or Agent may be asked to terminate the outside employment if he or she wishes to remain with the College. Outside employment will present a conflict of interest if it has an adverse impact on the College.

Confidentiality and Dissemination of Information:

As a public institution, Quincy College abides by the laws and statutes governing releases of information and confidentiality. In an effort to promote our mission and to foster positive community relations all inquiries from representatives of the media shall be immediately referred to the President of the College. No Employee or Agent is authorized to discuss College business with the media without the President's prior approval.

The official source of all public relations information about the College is the President's Office and as such, all requests for public relations information shall be referred to the President.

Employees and Agents of the College have a legal obligation to maintain confidentiality. As an Employee or Agent of Quincy College, you shall not disclose information determined to be confidential in nature in accordance with applicable laws and guidelines unintentionally by indiscrete conversation (for instance, on elevators, on the telephone, and/or in common/public area) or by careless handling of record documents and other documents containing confidential information. Confidential information includes, but is not limited to, the following examples:

Students records
Any document that lists a Social Security number wages and salaries
Employee data and records
Any other information designated as confidential by a member of the administration.

All Employees and/or Agents of Quincy College shall adhere to policies regarding confidentiality of student records, release of records, release of PHI, documentation of confidential information, Electronic Communication and Internet/Intranet Usage. Should an employee improperly use or disclose confidential business information, the employee will be subject to disciplinary action, up to and including termination of employment. This applies even if the employee does not get any benefit from releasing the information.

Proper Accounting:

It is necessary that all Employees and Agents comply with the accounting rules established by the College. The records of College must accurately reflect transactions. Undisclosed or unrecorded funds, assets or accounts of the College and/or its students will not be established for any reason, and false entries will not be made in the books and records of the College and/or it's students.

All disbursements made on behalf of the College, its students and/or their representatives are to be used only for the purpose described in documents supporting the disbursement. Personnel responsible for keeping the books and records of the College should communicate fully with management, internal auditing personnel, and independent auditors when the circumstances dictate.

The above procedures extend to all Employees and Agents involved in the disbursement of Quincy College funds and/or custodial accounts for which the College bears fiduciary responsibility including, but not limited to: petty cash; student accounts; cash receipts; credit cards; purchase orders; vendor credit lines; checking accounts. Use of the College's funds or assets for unlawful or improper use is strictly prohibited.

Any violation of this policy may be against criminal law and as such may result in disciplinary action up to and including possible termination of employment and possible criminal prosecution.

Legal Compliance

It is the policy of Quincy College to comply with all applicable laws and regulations. Individual employees have the responsibility of following all College policies and procedures, current collective bargaining agreements, and complying with all laws and regulations under which the College operates. Any violation of College policy may result in disciplinary action up to and including termination of employment.

Documentation:

Falsification of any documentation whether student related or not, may result in disciplinary action up to and including termination.

Original: June 2006