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					depaul   university



          Accountability and
O F F I C E   O F   I N S T I T U T I O N A L        C O M P L I A N C E


                              Letter from the president                                    2

                              Purpose                                                      3

                              Institutional Compliance program                             3

                              Reporting suspected non-compliance                           4

                              REPRESENTING THE UNIVERSITY                                  4

                                    Contacts with the media                                4

                                    Response to external legal, law enforcement,
                                    government of other outside inquiries                  5

                                    Contracts and agreements                               5

                                    Grants and Contract Proposals for External Funding     5

                                    Donations from the university                          6

                                    Honoraria                                              6

                                    Athletics                                              7

                                    University websites                                    8

                              CONFIDENTIAL & SECURE INFORMATION                            9

                                    Confidential information                               9

                                    Family Educational Rights and Privacy Act (FERPA)      10

                                    Information technology, security and confidentiality   11

                                    Acceptable use of technology                           11

                                    Passwords for systems and websites                     12

                                    Software licensing                                     12

                                    Adherence to copyright law                             12

                                    Intellectual property                                  13

                                    Use of university facilities                           13
CONFLICT OF INTEREST                              14

      Outside employment                          14

      Managing a conflict                         15

WORKPLACE CONDUCT                                 15

      Fraud                                       15

      Discriminatory harassment                   16

      Sexual harassment                           16

      Family and Medical Leave Act (FMLA)         17

      Threats and violence                        17

      Overtime and timekeeping                    18

      Employment of relatives                     18

      Political activities and public officials   19

      Environmental health and safety             20

      Duty to report crime and accidents          20


LEGAL DRINKING AGE COMPLIANCE                     21

FINANCIAL MANAGEMENT                              22

      Travel & entertainment                      22

      Gifts from the university                   22

      Gift acceptance and processing              23

      Proper use of consultants                   23

      Trademarks, fair trade and licensing        24

Financial aid code of conduct                     25

      Background                                  25

      Procedures                                  25

      Provisions                                  25
Letter from the president

       Dear DePaul Faculty, Staff & Student Workers:

                           DePaul University has always been, and still
                           remains, committed to conducting its business with
                           great integrity, accountability and dignity. The
                           university is faced with the challenge of operating in
                           an increasingly complex environment in which
                           governmental and legal oversight is growing more
                           and more stringent.

       To help address such challenges, the Office of Institutional Compliance,
       along with members of the DePaul community, have developed a Code
       of Conduct. The Code of Conduct highlights the policies most critical to
       working in higher education and at DePaul. Every DePaul employee
       (including faculty, staff, and student workers, full-time and part-time
       employees) is governed by the material in this document.

       The Code of Conduct is also a compliance tool that’s not just about
       following the letter of the law, but about creating an impact on the
       university’s environment and its employees’ ethical behavior. To this
       end, DePaul can illustrate to the university community exactly what its
       expectations are for its employees.

       By being a part of DePaul’s community, it is our responsibility to be good
       stewards of its resources. Your dedication to the university’s mission and
       its ethical standards contribute to DePaul’s overall success.


       Dennis H. Holtschneider, C.M., Ed.D.

                                             D e Paul universit y • CODE OF CONDUCT   2
The purpose of the Code of Conduct is              As changes and additions are made
to reiterate the fundamental                       to the Code’s source materials and
expectations DePaul University has for             applicable laws, the Code will
every one of its faculty and staff                 be updated and available online
members. Employees of DePaul are                   at
charged with upholding the Vincentian              DePaul’s policies are often updated,
mission and values of the university’s             and new policies are continually being
namesake, St. Vincent de Paul.                     considered. For the most up-to-date
Members of the DePaul community are                conduct policies, visit
expected to be honest and responsible    
with the university’s resources, to treat
each other with dignity and in a
collegial manner, and most                         Institutional
importantly, prepare DePaul’s students             Compliance
for a fulfilling and successful life ahead.        program
The Code of Conduct is meant to be                 DePaul University expects its faculty
used in several different ways. It can             and staff to properly handle and
serve as a quick reference to personal             protect its financial resources,
and business conduct questions, a                  operations, strategies and reputation.
starting point for familiarizing faculty           To do this, the university’s Audit
and staff with university policies, or as          Committee of the Board of Trustees
a way to learn how local, state and                agreed to develop a university-wide
federal laws and regulations impact the            compliance initiative, and soon after,
way business is conducted at DePaul.               the Office of Institutional Compliance
                                                   was formed.
In addition to statements relating to
certain conduct policies, the Code gives           The Executive Vice President serves as
sample situations in which the policies            DePaul’s Chief Compliance Officer,
apply. These samples serve as scenarios            responsible for the development and
to clarify the university’s stance on              administration of the university’s Office
certain policies.                                  of Institutional Compliance.

All DePaul employees are responsible               The department’s purpose is to foster a
for knowing and adhering to the                    culture of compliance and
policies mentioned in the Code of                  accountability that is consistent with
Conduct, in addition to its sources, the           DePaul’s mission. The compliance
Management Standards Handbook, the                 program addresses a number of
Faculty Handbook and the university’s              university activities that largely fall
Policies and Procedures website.                   under the framework of “Managing our
Faculty and staff must also abide by all           Business” and “Managing our Risk.”
applicable local, state and federal laws.

                                            D e Paul universit y • CODE OF CONDUCT           3
R e p ort i n g                                               representing
suspected                                                     THE UNIVERSITY
                                                              Contacts with the media
Employees with supervisory or fiscal                          DePaul’s faculty and staff may be
responsibility have a responsibility to                       contacted by reporters seeking expertise
report conduct related to university                          or university information. Faculty
activities and business that violates civil                   members are encouraged to participate
laws, university policies or DePaul’s Code                    in interviews that draw upon their
of Conduct. Community members who                             academic discipline to comment on
are not in a supervisory role or do not                       important issues of the day. Faculty
have fiscal duties are strongly encouraged                    should be clear with the interviewer that
to also report such conduct.                                  they are expressing personal views and
                                                              are not speaking on behalf of the
DePaul University takes allegations of
                                                              university. Faculty and staff members
misconduct seriously. Individuals who
                                                              who are asked by reporters to provide
knowingly make intentionally false or
                                                              information about DePaul's students,
purposefully misleading allegations of
                                                              administration or operations should
misconduct will be subject to appropriate
                                                              consult with a member of the Media
disciplinary action, which may include
                                                              Relations department prior to engaging
termination of employment.
                                                              in the interview to determine the
Any concerns regarding compliance or                          appropriate person to give the interview
alleged compliance violations should be                       and/or to obtain mutual agreement on
addressed through managerial channels                         topics to be addressed.
when appropriate. However, if there is an
instance where a manager is part of the                       DePaul’s campuses are considered closed
alleged non-compliance, or if an employee                     to the media unless Media Relations
                                                              approves a reporter’s presence and alerts
feels uncomfortable seeking resolution this
                                                              Public Safety. Approvals are often given to
way, he or she should report the concerns
                                                              accommodate faculty interviews and
using one of the following methods:
                                                              routine university news coverage.
• A letter stating an alleged impropriety can be
  mailed to the Office of Institutional Compliance,           For more information, contact the Media
  1 E. Jackson Blvd., 8th floor, Chicago, IL, 60604.
                                                              Relations Department or visit:
  Or the letter can be emailed to                            
• The compliance department can be called
  directly regarding any questions or concerns.               Q: Does Media Relations arrange
  The department’s number is (312) 362-6880.                     advertising or create marketing
• Other resources exist at the university,                       materials for university programs?
  depending on the situation:
  - The Office of the University Ombudsperson
    (for confidential discussions or support):                A: University Marketing Communications
    (312) 362-8707                                               handles paid advertising and marketing
  - Internal Audit: (312) 362-8392
                                                                 for the university. Media Relations helps
  - Office of Institutional Diversity and Equity:
    (312) 362-6872                                               promote DePaul’s position and
  - Human Resources: (312) 362-8500                              prominence in newspaper, broadcast and
  - Public Safety Office: (312) 362-8400,
    (773) 325-7777                                               Web media stories by working with the
  - Misconduct Reporting Anonymous Hotline:                      media and coordinating interviews,
    (877) 236-8390
                                                                 coverage and other related activities.
                                                       D e Paul universit y • CODE OF CONDUCT                4
Response to external legal, law                      For example, some contracts must
enforcement, government or other                     be approved and executed by an
outside inquiries                                    executive officer. Such contracts include
Any employee receiving a subpoena,                   those governing activities in more
summons, wage garnishment or other                   than one officer’s area of competence
legal request, on behalf of the university,          and responsibility, those that are
must immediately contact the Office of               for a duration of more than three years,
the General Counsel. The General                     those establishing an exclusive
Counsel’s office handles the release of              relationship with the other party,
legal documents when such requests                   and those containing an automatic
are appropriately made. The requests                 renewal provision.
generally require the university to
                                                     To review the Contract Requirements and
respond within a very short period
                                                     Procedures policy, visit:
of time.
For policy information, contact the Office
of the General Counsel or visit:                     Q: Must all contracts be submitted to the                               Office of General Counsel for legal review?

Q: What should I do if a government                  A: No. Most contracts under $50,000 do
   agent requests student or employment                  not need to be submitted for a legal
   records, but does not have                            review. All special-risk contracts must
   an authorized consent form for                        be submitted for legal review,
   such records?                                         regardless of the dollar value.

A: Government agents do not always have              Grants and Contract Proposals for
   the right to such records and, therefore,         External Funding
   all requests should be referred to the            The submission of a grant or contract
   Office of the General Counsel.                    proposal for external funding
                                                     constitutes a formal transaction
Contracts and agreements                             between DePaul and the funding
Executive officers, academic officers and            organization or agency. For that reason,
administrative officers of DePaul, or                proposal submissions must be handled
their specific designees, can negotiate              by the appropriate departments at
and execute contracts within their                   DePaul. The Office of Development is
appointed areas of expertise. However,               responsible for providing clearance to
all DePaul employees must follow the                 DePaul faculty and staff to formally
university’s Contract Requirements and               cultivate and solicit private funders. The
Procedures policy which provides                     Office of Research Services coordinates
thresholds for negotiation and execution             the proposal review and approval for all
authority and identifies contracts that              grant and contract proposals, regardless
require a legal review.                              of their funding source.

                                                     For policy information, visit:

                                             D e Paul universit y • CODE OF CONDUCT                   5
Submit your proposal for review using the            Donations from the university
Web-based Proposal Review Form located at:           It is generally inappropriate for any          member of the faculty or staff to make
form.html                                            gifts or donations in the name of DePaul,
                                                     to individuals, groups or organizations.
Q: After making a presentation at a
                                                     In certain circumstances, however, it
   professional conference, a
                                                     may be in the university’s best interest
   representative from ABC Foundation, a
                                                     to make such gifts or the university
   private granting agency, requested
                                                     may take part in a benefit or civic
   that I discuss with them the possibility
                                                     function that requires tickets to be
   of submitting a proposal in support of
                                                     purchased. Approval for exceptions to
   my project. How should I move
                                                     the general policy must be secured
   forward with this request?
                                                     from the Provost, the Executive Vice
A: Contact the Office of Corporate and               President (EVP)or the appropriate Vice
   Foundation Relations in the                       President(VP)/Dean.
   Development Office to discuss
                                                     For policy information, visit: policies.depaul.
   clearance requirements for the ABC
   Foundation, and for possible
   assistance in submitting the request.             Q: A member of our department has been
   To initiate this process go to                        battling an illness, and we’d like to
   Corporate and Foundation Relations’                   make a donation to an affiliated
   website at                         charitable organization. Can we use
   giving/cfr.aspx.                                      university funds for the donation?

Q: A colleague of mine is a program                  A: University funds cannot be used in
   officer with a state agency. She                     such a way, unless approved by the
   encouraged me to send her a proposal                 EVP, VP or Dean.
   for a research project we have been
   discussing. The deadline is quickly               Honoraria
   approaching, so I need to send it to              An honorarium is a payment made to an
   her by the end of the week. Can I send            individual, who is not an employee of
   her the proposal and copy the Office              the university, for services when payment
   of Research Services?                             of fees is not legally or traditionally
                                                     required. The intent of an honorarium
A: No. To be eligible for submission, the            payment is to show appreciation for
   proposal must pass through the review             participation in university educational,
   and approval process coordinated by               research or public service activities or
   the Office of Research Services. To               events. Payment is limited to guest
   expedite the process, immediately                 speakers and individuals offering other
   inform the Office of Research Services            non-commercial services that would not
   of the tight deadline and submit your             be expected to generate an invoice or
   proposal for review as soon as                    formal request for remittance.
   possible using the Web-based Proposal
   Review Form located at:

                                              D e Paul universit y • CODE OF CONDUCT                   6
To qualify for an honorarium payment,                   • Student-athletes should be treated in
a service must be characterized by all of                the same way as other students and
the following :                                          may not receive any “extra benefit”
                                                         generally not available to all students.
• The service is provided on a one-time or
                                                         Student-athletes cannot be given cash,
 highly infrequent basis,
                                                         loans or gifts of any kind, including
• The service provided has no tangible,                  birthday or holiday gifts by faculty
 deliverable product, such as a                          or staff.
 performance or speaking engagement,
                                                        • At no time should an image of a
• Payment for such services is not the                   student-athlete be used for any
 recipient’s primary source of income                    university or other publication without
                                                         the express permission of the
• Payment is generally considered to be                  Compliance Office of the Athletic
 a token of appreciation rather than                     Department. Student-athlete
 an obligation.                                          amateurism is strictly enforced. It
                                                         prohibits interactions with agents and
Due to tax compliance requirements, all
                                                         professional teams, and the use of a
honoraria are to be coordinated through
                                                         student-athlete’s name or likeness to
the Manager of Accounts Payable or the
                                                         promote commercial entities.
Tax Manager.
                                                        For policy information on the Use of
For policy information, visit:
                                                        Intercollegiate Athletics Photographs visit:
Q: We have a faculty member from another
                                                        Off-campus recruitment of prospective
    university producing a paper for our
                                                        student-athletes is limited to coaches and
    department at DePaul. Should I pay him
                                                        Athletic Department staff, and other
    an honorarium or as a consultant?
                                                        DePaul faculty and staff may only
A: Since the paper is a durable product,                become involved in the recruitment of
   the faculty member should be paid as a               prospective student-athletes when the
   consultant. To verify payment options,               prospect is visiting one of DePaul’s
   contact the Manager of Accounts                      campuses. A prospective student-athlete
   Payable or the Tax Manager.                          is a person who has begun ninth
                                                        grade classes.
As a Division I member of the National                  • Recruiting restrictions also extend to
Collegiate Athletic Association (NCAA)                   prospective student-athletes’ friends,
and the Big EAST Conference, DePaul                      family and coaches. If a faculty or staff
University is responsible for compliance                 member encounters a coach or an
with the rules both organizations set                    Athletic Department staff member with
forth. Some of the most important and                    a prospective student-athlete or family
sensitive rules include:                                 member, other than on campus as
                                                         noted above, he or she should not
                                                         approach or speak with them. In

                                                D e Paul universit y • CODE OF CONDUCT                 7
 addition, faculty and staff may not               DePaul’s website includes official pages,
 provide free or discounted tickets or             or those sanctioned by the university,
 transportation to any games or events             and unofficial pages, or those not
 to prospective student-athletes or their          sanctioned by DePaul. These include
 friends, family or coaches.                       staff, faculty, student organizations and
                                                   personal student pages. DePaul has no
For more information, visit the Athletic
                                                   control over and is not responsible for
Department’s compliance website at:
                                                   the accuracy or completeness of any
                                                   unofficial page. The views and opinions
Q: I am collecting donations for a silent          expressed on any unofficial pages are
   auction to benefit my church’s high             strictly those of its author.
   school. May the Athletic Department
                                                   For photos on university websites, a
   donate tickets?
                                                   signed photo release for each student or
A: No. NCAA rules prohibit the Athletic            non-employee in the image and
   Department from making contributions            copyright permission from the
   that may benefit prospective                    photographer is required. Photographers
   student-athletes in any way, including          often have different rates for various uses;
   charitable contributions to high                an additional fee may be required to use a
   schools and community colleges.                 photo from a brochure on the Web.
                                                   Permission from Enrollment Management
University websites                                and Marketing must be obtained prior to
To maintain a consistent DePaul brand              using any images from the university
and image, the university has several              website or print publications.
standards for its websites. Web pages              Unauthorized use of third-party photos
should have a primarily white                      can result in copyright infringement. For
background and the content should be               questions regarding photos and copyright,
clear, up to date, and easy to read. All           contact the Director of Enrollment
sites should provide an e-mail link to a           Communications in Marketing
webmaster/site manager. Sites must                 Communications.
also include a copyright and disclaimer
                                                   For website branding information, visit:
line with links at the bottom of the
page and links to the DePaul home
page on each page. The site’s home                 For policy information on the Use of EM&M
page should have the Tree of Wisdom                marketing photographs visit:
logo and DePaul signature, and a         
DePaul text link.
                                                   Photo releases may be obtained at:
Any website content that resides on      
university servers should be related to            %20Release%20Form.pdf
university business and should not
                                                   A sample photographer agreement may be
contain pornographic or obscene                    obtained at:
material, or links to these materials.             _downloads/Sample_Contract_Letter.pdf

                                            D e Paul universit y • CODE OF CONDUCT                8
Q: Are there any restrictions on the use of             Q: I am applying for a mortgage and was
   photos on my website?                                   wondering what type of information
                                                           DePaul would release about me.
A: No, not as long as the photos are of good
   quality, and you have a signed photo                 A: The university prefers that all requests
   release form for each person who will                   for employee information be made in
   appear on the site. In addition, DePaul                 writing, ensuring that all requests are
   must own the copyright on all photos                    made by bona fide agencies. Employee
   used. Unauthorized use of third-party                   authorization should be obtained for
   photos can result in copyright infringement.            any release of employee information. If
   Photo release forms and other information               employee authorization is not
   regarding copyright, are available through              obtained, information given to third
   Enrollment Management and Marketing.                    parties must be limited to present
                                                           employment status, current job title
                                                           and dates of employment.
CONFIDENTIAL &                                          Similarly, DePaul carefully maintains
SECURE INFORMATION                                      and protects all employees’ health
Confidential information                                information, required by the Health
DePaul is committed to protecting the                   Insurance Portability and
privacy of its employees, both during                   Accountability Act, or HIPAA.
and after their service at the university.
                                                        Q: I have requested a medical leave and
Whether employment information is
                                                           qualify for Short Term Disability (STD).
sought from bona fide agencies, such
                                                           What information is my department
as banks or mortgage companies, or
                                                           management given on my medical
from potential future employers,
DePaul is careful to release only valid
and pertinent information to                            A: The department will receive a notice
appropriate requests.                                      indicating the requested leave dates
                                                           and the approved leave period. To
For policy information, visit:
                                                           protect employee health information
                                                           as required under HIPAA and as
                                                           required by the university’s Health
                                                           Information Privacy policy, no
                                                           information on the medical condition
                                                           of the employee is provided to the

                                                        For policy information, visit:

                                                 D e Paul universit y • CODE OF CONDUCT                 9
Family Educational Rights and                    Directory information may be
Privacy Act                                      disclosed by DePaul, as well as other
A student’s personal information and             universities. Directory information
academic records are protected under             includes the student’s name, addresses
the Family Educational Rights and                (including e-mail), telephone number,
Privacy Act (FERPA). FERPA allows                date of birth, major, year in school,
students to inspect and review their             dates of attendance at the university,
educational records, amend their                 and full- or part-time status. This
educational records when appropriate,            information may be disclosed, unless
and have control over the disclosure of          the student has specifically requested
information from those records.                  the information not be released.
                                                 Although DePaul may release directory
Educational records contain                      information, the university is aware of
information directly related to a                the potential of identity theft and
student, and are usually maintained by           therefore does not disclose this
an educational agency or institution.            information indiscriminately.
These records include: files,
documents, and materials in various              For policy information, visit:
mediums such as handwriting, print,    
tapes, disks, film or microfiche.
Educational records do not include
                                                 Q: If a student indicates that he or she
“sole possession” notes, law
                                                    does not want any information
enforcement unit records, records
                                                    disclosed by the university, how should
exclusively for employees (except for
                                                    the university respond?
student employees whose records are
under FERPA), doctor-patient privilege           A: The university cannot release any
records and alumni records. Sole                    information on that individual.
possession notes are made by one
person as an individual observation or
recollection and are kept in the
individual’s possession. Sharing notes
with another person or placing them in
an area where they can be viewed
makes them educational records and
subject to FERPA.

                                         D e Paul universit y • CODE OF CONDUCT              10
Information technology, security                        Acceptable use of technology
and confidentiality                                     DePaul University provides an array of
DePaul University information systems                   computing resources to students, faculty,
and the data these systems contain are a                and staff, including e-mail, web hosting,
university resource of significant                      and Internet connectivity. These resources
importance and value. Much of the data is               are needed to provide educational access to
confidential and sensitive, and therefore,              the Internet, perform research and
must be safeguarded from unauthorized                   development, conduct business procedures
use and access. The university’s policies               and provide cost-effective communication.
and procedures serve to ensure that                     The university encourages the use of
system data, as appropriate, are accessible             computing resources at DePaul while
for the effective management and                        adhering to local, state and federal laws
legitimate educational purposes of the                  governing computer use.
university, while protecting the privacy of
                                                        Violations may include actions such as:
the individual and the confidentiality and
                                                        harmful actions towards minors, threats,
integrity of the data. Thus, system access
                                                        harassment, forgery, unsolicited email,
and data security procedures have been
                                                        unauthorized access, collection of
established to serve this end.
                                                        personal data, reselling services, service
For more information, visit:                            interruptions, physical security, and           copyright and trademark infringement.

Q: While I was on vacation, my supervisor               For policy information, visit:
   used my computer and accessed some         
   personal information I have stored on
   the hard drive. What can I do to prevent
   this kind of “snooping” in the future?               Q: I suspect that someone in my office is
                                                           using their PC to conduct illegal
A: DePaul University values the privacy rights
                                                           activities that violate the university’s
   of individuals using its computing
                                                           Acceptable Use/Network Security
   resources. While DePaul does not routinely
                                                           Policy. What should I do?
   monitor individual usage of its computing
   resources, users should be aware that all            A: Report the alleged illegal activities to your
   computing resources are the property of                 supervisor or to the DePaul University
   DePaul and may be accessed or monitored                 Computer Security Team by email at
   as necessary in the course of conducting       When reporting
   university business. Users who wish to                  violations of acceptable use, please
   maintain absolute privacy of information                provide the following information:
   should transmit and store that information
   on or through media other than DePaul                1. The date and time of the alleged activity
   computing resources.                                 2. Detailed descriptions of the alleged activity
                                                        3. Detailed descriptions of the effects which
                                                          were incurred due to this activity.

                                                D e Paul universit y • CODE OF CONDUCT                  11
Passwords for systems and websites                     • Or, the license agreement must state that
A computer password is the first level of               the software is free for academic use.
defense in protecting your computer,
                                                       For more information visit:
electronic files and other data. Many
attacks against computers rely on weak
passwords based on dictionary words and      
birthdates. A better way to protect data is
to create strong passwords for any system
                                                       Q: I recently downloaded a pop-up blocker
                                                          on my PC. Does this violate the
or site that requires a password.
                                                          university’s software licensing policy?
Recommendations can be found at:
                                                       A: Your actions may violate the university’s
                                                          policy. Many of the free pop-up blocker
                                                          and anti-spyware downloads available
Q: Is it acceptable to share your password                on the Internet are intended for home
   when you are in a crunch for time or                   or personal use only. Downloading this
   will be out of the office?                             type of software in a commercial
                                                          setting may violate the licensing
A: No. You should never share your                        agreement. Contact the DePaul Help
   password. If additional access is
                                                          Desk for assistance in determining if
   required, follow the procedure
                                                          the software is properly licensed.
   established to request access.
   Individuals who share their passwords               Adherence to copyright law
   are accountable for actions taken under             DePaul requires its faculty and staff to
   the login.                                          comply with applicable copyright laws.
                                                       Permission must be obtained from the
Software licensing
                                                       copyright owner to copy, distribute,
All DePaul University software must
                                                       transmit, download, publicly display, or
either be licensed by DePaul or be
                                                       make derivative works of materials for use
considered “freeware” (public domain).
                                                       that is not considered “fair use,” or where
If you wish to purchase software and are
                                                       no legal review has been conducted.
unsure if DePaul owns a license, call the
Help Desk at (312) 362-8765. If the                    The General Libraries assess fair use and
software is not licensed, the Help Desk                clear copyright permissions related to
can help you determine whether the                     library reserves (including electronic
software is freeware or if a license must              reserves). Faculty posting of copyrighted
be purchased.                                          material on Blackboard and other
                                                       course management systems is governed
• If the software is freeware, a faculty or
                                                       by the Copyright and Fair Use Policy.
 staff member must contact the
 manufacturer/distributor for                          For policy information, visit:
 permission to install the software.         
 (Permissions are still necessary even
 for freeware.)

                                              D e Paul universit y • CODE OF CONDUCT                12
DePaul also expects all users of its                    Copyright policy:
computer network to comply with                         policy.aspx?pid=168
applicable copyright laws. Upon notice
                                                        For more information regarding the appropriate
of an alleged copyright infringement or
                                                        use of intellectual property in the academic
actual knowledge of an infringement,
                                                        curriculum, please see the Copyright and Fair Use
DePaul will take all appropriate actions
under the Digital Millennium Copyright
Act (DMCA), which may include                           Q: I am a DePaul employee and I have
terminating an individual’s access to the                   drafted a training manual for the
DePaul network.                                             university. Am I the copyright owner of
                                                            this training manual?
For policy information, visit:,          A: Per the Discovery and Copyright policy,
or call the Office of the General Counsel.                 the answer depends on whether an
                                                           employee is generally classified as faculty
Reports of alleged copyright infringement
                                                           or as staff. In the absence of contractual
occurring on DePaul Web pages should be
                                                           provisions obligating the transfer of all or
directed to the university’s designated DMCA
                                                           some proprietary rights in a discovery to a
agent at
                                                           third party, faculty retain ownership of,
Q: I would like to download a journal                      and have the right to any income derived
   article for use in my classroom. Is this a              from, copyrighted material that they
   violation of U.S. Copyright laws?                       conceived or developed. However,
                                                           copyrighted material in which a third-
A: DePaul has guidelines and resources to                  party contract exists that defines the
   help determine whether such
                                                           disposition of copyrights, or in the case of
   downloading would be permissible
                                                           faculty, resulted from a written work
   under applicable copyright laws.
                                                           agreement, or work performed in
Intellectual property                                      accordance with the position of those
DePaul University, in accordance with its                  defined as staff, are considered “obligated
academic mission, places the highest value                 discoveries.” Obligated discoveries are
on the creation and dissemination of                       owned by the university and all of the
knowledge, and encourages its employees                    rights to the copyrighted material must
to develop and respect intellectual                        be assigned to the university in absence
property. Intellectual property includes,                  of a contract to the contrary.
but is not limited to, copyrightable
                                                        Use of university facilities
materials, such as scholarly writings,
                                                        DePaul has many state-of-the-art and
course materials, films and musical works,
                                                        unique spaces available for student,
and inventions such as computer
                                                        faculty and staff use for university-related
programs, algorithms, scientific processes,
                                                        business or activities. This includes
and business methods.
                                                        presentations on academic, professional
For more information regarding the ownership            or administrative development, university
of intellectual property developed by university        business or publicity.
employees, please see the Discovery and

                                               D e Paul universit y • CODE OF CONDUCT                  13
Any outside group that wishes to use                     CONFLICT OF
DePaul’s facilities must pay a fee.                      INTEREST
This includes programs that aren’t
meant for a DePaul audience,                             Outside employment
but are still reserved by a university                   While DePaul employees are allowed to
department or member. Events                             seek additional work outside of the
that charge a registration fee or                        university, it should not interfere with
admission to an event must also pay                      the individual’s time and performance
for facility usage. Free use of space is                 at DePaul. If there appears to be a
intended to benefit the students,                        conflict or a performance problem as a
faculty and staff of DePaul.                             result of outside employment, the
                                                         employee may be counseled according
For policy information visit:                            to Human Resource’s Progressive            Discipline policy.

Most university facilities have their own                If a faculty member chooses to engage
reservation forms and policies. For a detailed           in outside work, the activities must be
contact guide, visit: studentcenter.depaul.              professional in nature and contribute
edu/ConferenceCenter/ConferenceCenter.html               to the development of the faculty
-or-                                                     member or provide expertise to the              community. The time commitment for
LincolnPark.html                                         such work must not exceed the
                                                         equivalent of one day per work week.
Q: Can I sponsor an off-campus
       organization that wants to use a                  A college’s or school’s dean determines
       DePaul facility for its meeting?                  whether a faculty member’s additional
                                                         activities are within DePaul’s guidelines
A: Yes. University departments can sponsor
                                                         on activities outside of the university.
       events held by off-campus organizations.
                                                         Teaching at another institution while
       The off-campus organization will need to
                                                         under contract at DePaul is permitted
       pay a fee for use of DePaul spaces. The
                                                         only in instances where the dean has
       sponsoring department may be asked to
                                                         given written approval.
       provide its chart field information for
       billing purposes and a name of a staff            Q: Could I do occasional work for a family
       member as a sponsor or contact. For                  business while I’m employed at
       questions regarding space availability or            DePaul?
       to make reservations, contact the
       Student Center’s administration office.           A: As long as the outside work does not
                                                            interfere with or compromise your
                                                            responsibilities associated with your
                                                            position at DePaul, you may do
                                                            outside work.

                                                 D e Paul universit y • CODE OF CONDUCT             14
Managing a conflict                                      WORKPLACE
DePaul requires all employees whose                      CONDUCT
independence of judgement may be
impaired by a potential conflict of                      Fraud
interest to either refrain from the conflict             DePaul will investigate any reported
or disclose the conflict to a supervisor. In             fraudulent activities or misuse of
doing so, DePaul can help protect its                    university resources or property. Any
interests, assets and resources. Examples                individual found to have engaged in
of conflicts may include:                                fraudulent activities is subject to
                                                         disciplinary action by the university,
• approval decisions by an employee                      which may include termination and
 related to an outside vendor                            legal prosecution.

• an employee with a financial or other                  Definition: Fraud is a willful or deliberate
 personal interest in a company hired                    act or failure to act with the intention of
 for a project                                           obtaining an unauthorized benefit. Such
                                                         acts include:
In these and other situations, a
completed Certificate of Compliance                      • Forgery, making or altering documents
with Conflict of Interest Policy form                     or computer files with the intent
(Conflict of Interest form) is to be                      to defraud
completed and approved by the direct
supervisor of the employee.                              • Purposely inaccurate or fraudulent
                                                          financial reporting
For policy information, visit:            • Misappropriation or misuse of
                                                          university resources such as funds,
For the Conflict of Interest Form, visit:
                                                          supplies or other assets
Certificate.htm                                          • Improper handling or reporting of
                                                          monetary transactions
Q: My brother works for a printing
   company and we asked that                             • Authorizing or receiving compensation
   his company do work for us. Is this                    for goods not received or services
   a conflict?                                            not performed

A: You must disclose the relationship. In                • Authorizing or receiving
   addition, for this and any other conflict              compensation for hours not worked
   of interest, or appearance of a conflict
   of interest, you must fill out a Conflict             For more information, contact the Internal Audit
   of Interest Form, then review it with
   your manager and submit it to the
   Accounts Payable department.

                                                D e Paul universit y • CODE OF CONDUCT              15
Q: Should I confront an individual                   For more information visit:
   suspected of fraud or related           
                                                     Q: My supervisor has recently made
                                                        inappropriate cultural references that I
A: No. University employees should not
                                                        find offensive. I am extremely
   initiate investigations or questioning
                                                        uncomfortable with the situation, but
   on their own. All suspected incidents
                                                        fear that the fall-out from reporting it
   of fraudulent or related misconduct
                                                        would be worse than putting up with
   should be reported to Internal Audit.                the behavior. What can I do?

Discriminatory harassment                            A: Report alleged incidents of discrimination
DePaul has a long standing commitment
                                                        to the Office of Institutional Diversity and
to the diversity of its faculty, staff and
                                                        Equity. The university prohibits retaliation
student body. The university is committed
                                                        or threat of retaliation in any form
to preserving an environment that
                                                        against employees who have filed
respects the personal rights and dignity of
                                                        discrimination complaints in good faith.
each member of its community. It is
DePaul policy that no person shall be the            Sexual harassment
object of discrimination on the basis of             The learning and work environment
race, color, ethnicity, religion, sex, gender,       should be free from inappropriate
sexual orientation, national origin,                 conduct of a sexual nature. Sexual
age, marital status, parental status, family         harassment is illegal and will not be
relationship status, physical or mental              tolerated at DePaul University. In
disability, military status, or any other            accordance with DePaul’s Anti-
status protected by local, state, or                 Discrimination and Anti-Harassment
federal law in its employment or its                 Policy and Procedures, incidents of
educational settings.                                sexual harassment should be reported
                                                     to either a person in a supervisory
The Office of Institutional Diversity and            capacity or to the Office of Institutional
Equity is responsible for receiving,                 Diversity and Equity. In addition,
processing and resolving complaints of               all members of the community who
discrimination or harassment. All                    serve in a supervisory capacity, such as
members of the university who serve in               deans, managers and department
a supervisory capacity, such as deans,               chairs are responsible for reporting
managers and department chairs, are                  all complaints of sexual harassment
responsible for relaying all complaints              to the Office of Institutional Diversity
of discrimination or harassment to the               and Equity. Employees who engage
Office of Institutional Diversity and                in conduct that is prohibited by the
Equity. Employees who engage in                      Anti-Discrimination and Anti-
conduct that is prohibited by the Anti-              Harassment Policy and Procedures
Discrimination and Anti-Harassment                   will be subject to disciplinary action,
Policy and Procedures will be subject to             up to, and including, termination.
disciplinary action, up to and
including, termination.                    

                                             D e Paul universit y • CODE OF CONDUCT              16
Q: During a recent school-sponsored                  be found in the university’s Family and
   social event held off campus after                Medical Leave Act policy. The university
   normal work hours, a colleague of                 uses an external vendor for
   mine made inappropriate statements                administration of FMLA benefits.
   to me of a sexual nature. My                      Questions regarding FMLA should be
   colleague’s behavior made me very                 directed to the Office of Human
   uncomfortable, but it occurred outside            Resources.
   the workplace after normal work
                                                     For more information, visit:
   hours. What can I do?
A: Work-related events, such as business             Q: I have been scheduled for a surgical
   travel, or work-sponsored events, even
                                                        procedure that will involve a recovery
   if they are held off campus, are
                                                        period of at least three weeks. How much
   considered extensions of the workplace.
                                                        notice do I need to provide my manager?
   You should report the incident to your
   manager or to the Office of Institutional         A: You should inform your manager of
   Diversity and Equity.                                your plan to be absent as soon as
                                                        possible. In addition, you will need to
Family and Medical Leave Act
                                                        contact the Office of Human Resources
                                                        to begin the application process.
The Family and Medical Leave Act
(FMLA) is a federal law that provides                Threats and violence
for leaves of absence for circumstances              DePaul strives to maintain a work
that require employees to be absent                  environment free from intimidation,
from work for extended periods of time               threats (direct or implied) or violent
due to the employee’s serious health                 acts. The university will not tolerate
condition, the serious health condition              intimidating, threatening or hostile
of an immediate family member (child,                behavior of any kind. Employees who
spouse, or parent), the birth of a child,            engage in conduct that is prohibited by
or the placement of a child with an                  the Threat Assessment and Reporting
employee for adoption or foster care.                Policy will be subject to disciplinary
Under the provisions of the FMLA,                    action, up to and including
an eligible employee’s position                      termination. As per the Threat
and benefits are protected for up to                 Assessment and Reporting Policy,
12 weeks of unpaid leave in a rolling                employees who believe they have been
12-month period.                                     subject to threatening or violent
                                                     behavior in the workplace, should
An employee with a serious health
                                                     report the incident to their supervisor,
condition, requiring an absence of more
                                                     Public Safety or Human Resources.
than three consecutive days, should
contact Human Resources immediately.                 For more information, visit:
Details regarding eligibility criteria and 
employee rights and responsibilities can

                                             D e Paul universit y • CODE OF CONDUCT              17
Q: A colleague in my office has developed          employees must authorize overtime
   a reputation for having a bad temper.           before it is worked.
   Once at a meeting my colleague was
                                                   Questions regarding overtime
   so upset that he threw a stapler across
                                                   compensation should be directed to the
   the room in a rage. After a recent
                                                   Office of Human Resources.
   disagreement with him about a work-
   related issue he waited for me in the 
   lot where I park my car and confronted
   me in an aggressive manner. He said
   that I was “not being fair” and that it
   made him “extremely angry.” What
   should I do?                                    Q: My supervisor directed me to add five
                                                      hours that I did not work to my time
A: DePaul has a no tolerance policy                   report as recognition for my contribution
   against intimidating and hostile                   to an important project. Is that an
   behavior of this kind. The incident                acceptable form of recognition?
   should be reported to your manager
   and to the Public Safety Office or              A: No. The time report is an official
   Human Resources. A prompt and                      document that should reflect the actual
   thorough investigation of the incident             hours worked by the employee.
   will be conducted and appropriate                  Falsification of a time report is a
   action will be taken.                              fraudulent act that is subject to discipline
                                                      up to and including termination.
Overtime and timekeeping
Non-exempt employees are required to               Employment of relatives
complete a time report to receive pay.             Relatives of DePaul employees do not
Time reports are official records that             receive preferential consideration for
must accurately reflect the time worked.           employment at the university. Relatives
Falsifying a time report is a serious act of       may work in the same department,
misconduct that can lead to discipline up          though no individual should be directly
to and including termination.                      supervised by a relative. Additionally,
                                                   care should be given to avoid situations
DePaul complies with all applicable laws           where relatives are responsible for
governing wage and hourly                          checking or verifying each other’s work.
administration in the workplace. In                Relatives are persons related by blood,
accordance with the Fair Labor                     marriage or legal procedure.
Standards Act (FLSA), non-exempt
employees will receive pay equal to one            If a conflict occurs, attempts will be
and one-half times the regular rate of pay         made to find a suitable position within
for the hours they work in excess of 40            the department or university where one
hours in a work week. Overtime is paid             of the employees may transfer. If no
based on actual time worked, not time              accommodations can be made, one of
compensated. Time compensated is time              the employees may be asked to resign.
not worked, such as vacation, sick or
                                                   For more information, visit:
holiday pay. Supervisors of non-exempt

                                           D e Paul universit y • CODE OF CONDUCT                  18
Q: My new external grant includes funding              Employees are encouraged to
   for several part-time positions. As                 participate in the election process as
   principal investigator and hiring manager,          long as it is not during the hours they
   I plan to fill one of those positions by            work for the university. However,
   hiring my daughter. Does the university’s           DePaul employees are prohibited from
   Employment of Relatives policy apply to             speaking or acting on behalf of the
   externally funded grant positions too?              university when involved in political
                                                       activities. Also prohibited is the use of
A: Yes. The university’s Employment of                 DePaul letterhead, university lists,
   Relatives policy states that no                     phones or office space to support a
   individual shall be employed in a                   specific political candidate.
   department or unit under the
   immediate supervision of a relative                 When a university-related activity requires
   regardless of the source of funding.                contact with a political official, whether
                                                       from the City of Chicago, or on state or
Political activities and contacts                      federal levels, it should first be cleared
with public officials                                  through the Office of Community and
Political participation is a sensitive                 Government Relations.
issue at DePaul that must be carefully
understood and followed. The Higher                    For policy information, visit:
Education Act of 1998 requires               
institutions that receive federal aid to
promote voter registration. A “good
faith effort” should be made to                        Q: As I was walking to a building on
distribute voter registration forms to all                campus, I noticed a sign with a political
enrolled students.                                        candidate’s name on it in an office
                                                          window of a DePaul employee. Is this
DePaul is also subject to many political                  against university policy?
limitations due to its non-profit, tax-
exempt status. For example, the                        A: Yes. The sign could be construed as an
university or anyone on behalf of the                     endorsement of the candidate named
university cannot endorse or fund any                     on the sign by the university. DePaul’s
political activity or individuals running                 status as a tax-exempt organization
for public office, whether at the local,                  places limits on the types of allowable
state or federal level. Doing so could                    political activities. In this instance, the
jeopardize DePaul’s tax-exempt status.                    endorsement concern can be alleviated
                                                          by positioning the sign so it is only
                                                          visible from the inside of the office.

                                              D e Paul universit y • CODE OF CONDUCT                19
Environmental health and safety                             exiting the building, and the assembly
DePaul takes the safety and well-being                      point for your work group after you
of the entire university community very                     have exited the building.
seriously. By law, DePaul is required to
                                                         Specific information regarding the university’s
follow the Occupational Safety and
                                                         evacuation procedures can be found at:
Health Administration’s (OSHA) and the
Environmental Protection Agency’s
(EPA) regulations, other local and state                 Duty to report crime and accidents
environmental/safety codes, regulations                  The university's procedures and
and ordinances, and the internal                         practices for reporting crime and other
policies of the university. This applies to              suspected misconduct promote good
chemical inventory and storage,                          business practice and comply with
compilation of Material Safety Data                      various laws.
Sheets (MSDS), disposal of hazardous
                                                         The university, through its Public
waste, training for employees and
                                                         Safety Office and in concurrence with
students, and provision of “right-to-
                                                         the Jeanne Clery Disclosure of Campus
know” information.
                                                         Security Policy and Campus Crime
Environmental, health and safety information             Statistics Act, uniformly and consistently
pertaining to DePaul University can be found at          reports all serious crimes on campus to Hard copies are also                   the proper municipal authority and
available from The Office of Risk Management             provides statistics on these crimes in its
and Environmental Health and Safety.
                                                         Annual Safety and Security Information
For policy information, visit:                           Report and Fire Safety Report.            Employees who witness a crime being
                                                         committed on or around DePaul’s            campuses should report the information
                                                         to DePaul Public Safety. Employees              who are Campus Security Authorities
ments/Waste%20Disposal%20Guide_08_pdf.pdf                (CSAs) under the Clery Act must
                                                         promptly report all crimes reported to              them to Public Safety as soon as
                                                         possible. CSAs are university faculty and
Q: It is unclear to me what I should do in               staff members with "significant
   the event of a fire or other emergency                responsibility" for student and campus
   that requires evacuating my building.                 activities. A letter is sent annually to
   Where do I go to get this information?                individuals identified as CSAs reminding
                                                         them of their responsibilities. Crimes
A: Your manager can provide you with the                 that occur off-campus involving DePaul
   evacuation procedures for your work
                                                         students or at DePaul sponsored events
   area. It is important to address the
                                                         should be reported to local municipal
   following areas: the type of alarm or
                                                         authorities and Public Safety. Employees
   announcement, location of emergency
                                                         who report an incident to Public Safety
   exits, how to request assistance in
                                                         may also be required to report the

                                                D e Paul universit y • CODE OF CONDUCT               20
matter to DCFS pursuant to their                   For policy information, visit:
obligations as a mandated reporter of    
child abuse and neglect.                 

The Illinois Abused and Neglected Child            Q: I think I’ve been the victim of theft,
Reporting Act (325 ILCS 5) mandates                   what should I do?
that all university personnel who have
                                                   A: If the crime happens on or to university
reasonable cause to believe that a child
                                                      property, contact the Public Safety
under the age of 18 known to them in
                                                      Department and make sure that a
their professional or official capacity
                                                      Security Report is issued. Then notify the
may have been subjected to physical or
                                                      Office of Risk Management if an
sexual abuse, may be at risk of physical
                                                      insurance claim needs to be filed. A copy
or sexual abuse, or is being deprived of
                                                      of the Security Report is needed to
the proper or necessary care
                                                      support the insurance claim. DePaul does
immediately report such mistreatment
                                                      not provide insurance coverage for
to the Illinois Department of Children
                                                      employee or student personal property. If
and Family Services ("DCFS") by
                                                      loss of personal property occurs, an
calling DCFS' child abuse hotline at
                                                      employee or student should consult their
1-800-25-ABUSE. Mandated reporters
                                                      homeowner’s or renter’s insurance policy.
are individually responsible for
ensuring that certain conduct is
reported directly to DCFS and reporting
this conduct to DePaul Public Safety, a            Drug-Free
supervisor or administrator will not               Workplace and
fulfill this legal obligation. Employees           Legal Drinking
who report an incident to DCFS may                 Age Compliance
also be required to report the matter to
                                                   As an institution receiving federal financial
Public Safety pursuant DePaul's crime
                                                   assistance, DePaul University complies
reporting guidelines.
                                                   with the Drug Free Workplace Act and the
Reporting an accident is just as                   Drug Free Schools and Communities Act.
important as reporting a crime. If an              The State of Illinois prohibits the sale, use,
accident occurs on university property,            or possession, of alcoholic beverages by
the Public Safety Department should be             persons who are under 21 years of age.
notified so that an accident report will           Alcohol may be served to those of legal age
be issued. If the accident results in an           at university events, including classes.
injury to a DePaul employee, the Office            Event sponsors are responsible for having
of Risk Management should be                       adequate control measures in place to
contacted. If an injury occurs to                  ensure that persons under 21 years of age
another person or damages another                  and persons who are obviously intoxicated
person’s property, contact the Office of           are not served alcohol.
Risk Management.

                                           D e Paul universit y • CODE OF CONDUCT               21
Q: Our academic department is hosting                   expenditure, and the location of the
   an event and plans to have food and                  expenditure. An original receipt is
   alcoholic beverages available to                     required for all transactions, except
   guests. Can undergraduate students                   meals of $25 and under.
   enrolled in the program be included
   on the list of invitees?                             Reimbursement for local travel, generally
                                                        considered travel that does not require
A: Undergraduate students may be                        overnight lodging, normally includes
   invited to the event. However, the                   trips to non-routine destinations for
   event sponsor is responsible for                     business purposes that are not part of
   ensuring alcoholic beverages are not                 the normal and usual position
   served to persons under 21 years of                  requirements. Local travel does not
   age. Proper controls may include                     include normal commuting costs.
   hiring a professional bartender to                   DePaul does not reimburse for normal
   serve alcohol, on-site security, the                 commuting costs.
   presence of a university
   representative, a method of age                      For policy information, visit: policies.
   identification, and monitoring of          
   the event.
                                                        Q: I had to go to a suburban campus for
For policy details, go to: policies.depaul.                 a meeting. Is my mileage or travel
edu/policy/policy.aspx?pid=259                              expense reimbursable?

                                                        A: Yes. As long as the expenses are
                                                           not part of your daily travel
FINANCIAL                                                  or commuting costs, travel expenses
MANAGEMENT                                                 are reimbursable when visiting
                                                           other campuses for business-
Travel and entertainment
                                                           related functions.
The university will reimburse employees
and university guests performing                        Gifts from the university
services for the benefit of the university              In general, university funds are not to
for reasonable business expenses                        be used to purchase a gift for an
incurred while conducting authorized                    employee or group of employees.
university business. Employees are                      Any such gifts must be purchased
encouraged to use their university Pro                  with personal funds or the
Card for expenses in lieu of incurring                  department may take up voluntary
out-of-pocket expenses. When not using                  collections for such purchases.
a Pro Card, employees are expected to                   Please note that the university must
pay expenses out-of-pocket.                             report and tax, as compensation, all
                                                        non-de minimus non-cash gifts it
All reimbursement requests must be
                                                        provides to employees. Refer to the
substantiated by documentation of a
                                                        Gifts to Employees policy for
clearly stated business purpose, the
                                                        additional information.
amount of each separate
expenditure, the date of the

                                              D e Paul universit y • CODE OF CONDUCT               22
As an exception, with the approval of                Advancement must be contacted.
the appropriate Dean or Vice                         Advancement will coordinate an
President, a unit/department may                     internal review to determine if the
provide a modest length of service/                  university can accept the gift and to
retirement gift to an employee in                    arrange for proper transmission of
recognition of their years of service to             any accepted gifts to the university.
the university.
                                                     Q: Our area would like to solicit private,
In addition, with the approval of the                   charitable donations in order
appropriate Dean or Vice President,                     to help financially support our
a unit/department may send flowers                      activities. Do we need to obtain
upon the death of an employee,                          university approval?
or an immediate family member of
an employee.
                                                     A: Yes. You must obtain approval to
                                                        solicit private, charitable donations
For policy information, visit: policies.depaul.         that benefit your program from the
edu/policy/policy.aspx?pid=44                           Office of Advancement. You should
                                                        obtain approval from the
Q: A close family member of an
                                                        Advancement gift officer that works
   employee just passed away. Can my
   department purchase a flower                         with your area, and you must adhere
   arrangement for the funeral?                         to all existing university solicitation
                                                        clearance procedures. Furthermore, if
A: With the approval of the appropriate                 you want to conduct a fundraising
   Dean or Vice President, a                            event, you must obtain additional
   unit/department may send flowers                     clearance from the Vice President of
   upon the death of an employee or an                  Development via the fundraising
   immediate family member of an                        event clearance form. The
   employee. Normally, the cost of the                  fundraising event clearance form is
   flowers should not exceed $150.00. For               available at
   memorial donations to outside                        Forms/FundraisingEvent.aspx. All
   organizations, see the Gifts or                      donations you receive must be
   Donations from the University policy.                delivered to Advancement Gift
                                                        Processing to ensure that donors
Gift Acceptance and Processing
                                                        receive legal credit and proper
All private donations (gifts) received
by any area of the university must be
sent to the Office of Advancement                    To view the Gift Acceptance and Processing
for processing within one working                    policy go to:
day of receipt of the donation, to                   policy/policy.aspx?pid=229
ensure the donor receives legal credit
                                                     Proper use of consultants
and proper acknowledgement.
                                                     It is expected that university
If a donor has expressed an intent to                activities will be carried out to the
give a gift of real or personal                      maximum extent possible by
property, securities, a planned gift, or             utilizing the services of regular
a gift of $250 or more, the Office of                employees. When services required

                                           D e Paul universit y • CODE OF CONDUCT            23
cannot be provided adequately by                        implications. To ensure compliance
regular employees within the scope                      with overtime laws, contact Human
of their university employment,                         Resources regarding compensation.
consultants or independent
contractors may be utilized. The
                                                     Trademarks, fair trade and licensing
                                                     DePaul owns and controls several
university is responsible for
                                                     names and logos associated with the
analyzing each pay for services
                                                     university, such as the Tree of Wisdom,
situation to determine whether the
                                                     the DePaul signature, Coat of Arms, the
work performed should be treated as
                                                     Seal, and the Blue Demons athletic
dependent (employee) or inde-
                                                     logo. Any variation or modification to a
pendent (external consultant/
                                                     DePaul trademarked symbol or logo is
vendor) based on Internal Revenue
                                                     illegal, regardless of its intended use.
Service (IRS) guidelines. The Use
of Independent Contractors/                          To ensure compliance with university
Consultants policy provides                          policies and brand standards, contact
guidelines to determine dependent                    the Department of University
versus independent status.                           Marketing Communications prior to
                                                     using the Tree of Wisdom or the DePaul
When consultants or independent
                                                     signature on printed materials or
contractors are necessary, the
                                                     electronic media. Contact the Director
Manager of Accounts Payable or the
                                                     of Sports Marketing and Licensing for
Tax Manager should be contacted for
                                                     permission prior to using the Blue
aid in determining if the service
                                                     Demons Athletic logo on any material.
provider should be paid as an
                                                     The trademark or copyright symbol
employee or as an independent
                                                     (™ or ®) must be used next to DePaul
contractor (external consultant/
                                                     logos on any item that could be sold,
vendor) based on Internal Revenue
                                                     regardless of whether you intend to sell it.
Service (IRS) guidelines.

For policy information, visit: policies.             DePaul conducts its business in a                 socially responsible manner that
                                                     supports the ideals of its namesake, St.        Vincent de Paul, and his strong beliefs
                                                     in social justice. The university has a
Q: If a current DePaul employee is
                                                     Fair Business Practice Committee that
   providing services to another
                                                     reviews labor conditions found in
   department independent of her
                                                     factories of DePaul licensees, and
   position, should she be paid as an
                                                     recommends minimum standards with
   employee or as a consultant?
                                                     which licensees are required to comply.
A: This employee must be paid as an                  The university expects its licensees to
   employee and her payment                          adopt business practices that are
   arrangements must be made                         compatible with these standards.
   according to university policies and
                                                     For policy information, visit: policies.
   procedures. If the employee is paid
   hourly, there may be overtime

                                           D e Paul universit y • CODE OF CONDUCT               24
Q: I am ordering a novelty item for my                 Thereafter, such officers, employees, and
   department event on which I would like              agents shall be annually informed of its
   to use a DePaul logo. Who should                    provisions and shall annually certify in
   I contact? Do I need to use the                     writing their understanding and
   trademark symbol?                                   acceptance of this Code. This Code will
                                                       also be attached to the University’s Code
A: Contact the Director of Sports Marketing            of Conduct maintained by the Office of
   and Licensing in Athletics to discuss the           Institutional Compliance.
   use of a DePaul logo for your project. The
   Director will advise you on whether and             The Financial Aid Code of Conduct is
   how to use any DePaul mark and also                 based upon Section 493 of the HEOA and
   discuss your next steps for proceeding              shall be interpreted consistently with its
   with the order. You must use the                    provisions and any regulations promul-
   trademark symbol, even though you                   gated there under. The determination of
   plan to give the items away.                        whether conduct of a DePaul officer,
                                                       employee, or agent falls within this Code
                                                       shall be made by the Office of Financial
                                                       Aid, in consultation with the Office of the
                                                       General Counsel. All questions regarding
                                                       this Code should be directed to the
                                                       Director of Financial Aid Compliance at
Background                                             (312) 362-8348.
DePaul University participates in the
                                                       If there is uncertainty as to whether
Federal Direct Loan Program and receives
                                                       conduct falls within the restrictions of this
Title IV federal loans for its students. As a
                                                       Code, officers, employees, and agents
condition of this participation and to
                                                       mus t consult with the Director of
comply with the Higher Education
                                                       Financial Aid Compliance in advance of
Opportunity Act of 2008 (“HEOA”),
                                                       proceeding with the conduct. Officers,
DePaul has instituted this Financial Aid
                                                       employees, and agents subject to this
Code of Conduct (“Code”) to ensure the
                                                       Code who receive any of the “gift”
integrity and compliance of its
                                                       exceptions identified in paragraph two
administration of student loan programs.
                                                       must also report them in writing to the
Though DePaul as a direct lender may not
                                                       Director of Financial Aid Compliance.
be subject to every circumstance detailed
below, the University nonetheless prefers              Provisions
to take an expansive approach to combat                1. Ban on Revenue Sharing
any actual or appearance of a conflict of              DePaul University shall not enter into any
interest with respect to student loans.                revenue-sharing arrangements with any
                                                       lender. This includes any arrangement
                                                       between DePaul and a lender that results
All DePaul University officers, employees,
                                                       in the lender paying a fee or other benefits
and agents with responsibilities for
                                                       (such as a share of the profits) to DePaul,
financial aid or student loans must
                                                       its officers, employees or agents, as a result
comply with this Code. Such officers,
                                                       of the University recommending the
employees, and agents must be initially
                                                       lender to students or their families.
trained on the Code’s requirements.
                                               D e Paul universit y • CODE OF CONDUCT                25
2. Ban on Gifts                                        DePaul as an integral part of a
DePaul has a Gifts to Employees Policy                 training session that is designed to
(“Gifts Policy”) that outlines guidelines and          improve the service of a lender,
restrictions associated with the acceptance            guarantor, or servicer of education
of gifts offered by third parties to University        loans to the institution, if such
employees and business units. In addition              training contributes to the
to the Gifts Policy, DePaul officers,                  professional development of the
employees, and agents employed by the                  officer, employee, or agent;
Office of Financial Aid or otherwise
                                                      • Favorable terms, conditions, and
responsible for education loans will also be
                                                       borrower benefits on an education
bound by the following gift restrictions:
                                                       loan provided to a student employed
No DePaul officer, employee, or agent                  by DePaul, if such terms, conditions,
employed by the Financial Aid office or                or benefits are comparable to those
otherwise responsible for education loans              provided to all DePaul students;
shall solicit or accept any gift from a
                                                      • Entrance and exit counseling services
lender, guarantor, or servicer of education
                                                       provided to borrowers to meet
loans. This ban even applies to gifts whose
                                                       DePaul’s responsibilities for entrance
value falls below the limits of DePaul’s Gifts
                                                       and exit counseling as required by the
Policy. For the purposes of this Code, the
                                                       HEOA, so long as DePaul’s staff
term “gifts” includes but is not limited to
                                                       controls the counseling and it does
any cash, gratuity, favor, discount,
                                                       not promote the products or services
entertainment, hospitality, loan, or other
                                                       of any specific lender;
item having a monetary va lue of more
than a de minimus amount. The term as                 • Philanthropic contributions to
used herein includes a gift of services,               DePaul from a lender, servicer, or
transportation, lodging, or meals, whether             guarantor of educational loans that
provided or paid for directly or reimbursed            are unrelated to educational loans or
after the expense has been incurred.                   any contribution from any lender,
                                                       guarantor, or servicer that is not made
For the purposes of this Code, the term
                                                       in exchange for any advantage related
“gifts” shall not include any of the items
                                                       to education loans; or
below. However, officers, employees,
and agents subject to this Code must                  • State education grants, scholarships,
report receipt of any of the following                 or financial aid funds administered by
in writing to the Director of Financial                or on behalf of a state.
Aid Compliance:
                                                      A gift from a lender, guarantor, or servicer
• Standard material, activities, or                   of education loans to a family member or
 programs on issues related to loans or               other acquaintance of an individual
 financial information, such as a                     subject to this code is prohibited if
 brochure, a workshop, or training;                   (1) given with the individual’s knowledge
                                                      and acquiescence, (2) with reason to
• Food, refreshments, training, or
                                                      believe it was given because of his or her
 informational material furnished to
                                                      official University position. For additional
 an officer, employee, or agent of

                                              D e Paul universit y • CODE OF CONDUCT            26
restrictions on gifts, please refer to                  financial counseling materials (provided
DePaul’s Gifts Policy.                                  they disclose the identity of any lender
                                                        that assisted in their preparation), or
3. Ban on Contracting Arrangements
                                                        short-term, non-recurring staffing during
No DePaul officer, employee, or agent
                                                        local, state, or federal emergencies.
employed in the Office of Financial Aid or
otherwise responsible for education loans               7. Ban on Advisory Board
shall accept from any lender or its affiliate           Compensation
any fee, payment or other financial benefit             No DePaul officer, employee, or agent
(including the opportunity to purchase                  employed in the Financial Aid office or
stock) as compensation for any type of                  otherwise responsible for education
consulting arrangement or other contract to             loans, who serves on an advisory board,
provide services to or on behalf of a lender,           commission, or group established by
guarantor, or servicer of education loans.              lenders or guarantors, shall receive
                                                        anything of value from the lenders or
4. Ban on Certain Interactions
                                                        guarantors except for reimbursement of
with Borrowers
                                                        reasonable expenses incurred in serving
For any first-time borrower, DePaul
                                                        on such board, commission, or group.
shall not assign the borrower’s loan to a
particular lender or refuse to certify, or              8. Ban on Other Conflicts of Interest
delay certification of, any loan based on               DePaul has a Conflicts of Interest Policy
the borrower’s selection of a particular                which requires University employees to
lender or guaranty agency.                              either refrain from or disclose their
                                                        involvement in matters where any conflict
5. Ban on Offers of Funds for
                                                        or appearance of conflict between personal
Private Loans
                                                        and University interests exists. In addition
DePaul shall not request or accept
                                                        to this Conflicts of Interest Policy, all
from any lender any offer of funds to be
                                                        DePaul officers, employees, and agents
used for private education loans,
                                                        employed in the Office of Financial Aid
including an opportunity pool loan, to
                                                        or otherwise responsible for education
students in exchange for the institution
                                                        loans are prohibited from having any
providing concessions or promises
                                                        conflicts of interest with respect to their
regarding providing the lender with a
                                                        responsibilities for Title IV education loans.
specified number of loans or loan
volume, or a preferred lender                           In addition to the items above, as a
arrangement for such loans.                             member of the National Association of
                                                        Student Financial Aid Administrators
6. Ban on Staffing Assistance
                                                        (NASFAA), DePaul also follows the
DePaul shall not request or accept from
                                                        standards established in NASFAA’s
any lender any assistance with call center
                                                        Statement of Ethical Principles and Code
staffing or Office of Financial Aid staffing.
                                                        of Conduct for Institutional Financial Aid
However, this Code shall not be construed
                                                        Professionals, including the standards
to prohibit DePaul from requesting or
                                                        listed in #9 below. See
accepting assistance from a lender related
to professional development training,

                                                D e Paul universit y • CODE OF CONDUCT                27

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