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depaul university
CODE
of CONDUCT
Integrity
Accountability and
Dignity
DEPAUL UNIVERSITY
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
of
TABLE
CONTENTS
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
DRUG-FREE WORKPLACE AND
LEGAL DRINKING AGE COMPLIANCE 21
FINANCIAL MANAGEMENT 21
Travel & entertainment 21
Gifts from the university 22
Gift acceptance and processing 22
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.
Sincerely,
Dennis H. Holtschneider, C.M., Ed.D.
President
D e Paul universit y • CODE OF CONDUCT 2
Purpose
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 compliance.depaul.edu.
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 policies.depaul.edu.
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
non-compliance
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
appropriate person to give the interview
Any concerns regarding compliance or
and/or to obtain mutual agreement on
alleged compliance violations should be
topics to be addressed.
addressed through managerial channels
when appropriate. However, if there is an DePaul’s campuses are considered closed
instance where a manager is part of the to the media unless Media Relations
alleged non-compliance, or if an employee 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
routine university news coverage.
using one of the following methods:
• A letter stating an alleged impropriety can be For more information, contact the Media
mailed to the Office of Institutional Compliance, Relations Department or visit:
1 E. Jackson Blvd., 19th floor, Chicago, IL, 60604.
Or the letter can be e-mailed to newsroom.depaul.edu/ContactUs/index.html
compliance@depaul.edu.
• The compliance department can be called Q: Does Media Relations arrange
directly regarding any questions or concerns. advertising or create marketing
The department’s number is (312) 362-6880.
materials for university programs?
• Other resources exist at the university,
depending on the situation: A: University Marketing Communications
- The Office of the University Ombudsperson
(for confidential discussions or support): handles paid advertising and marketing
(312) 362-8707 for the university. Media Relations helps
- Internal Audit: (312) 362-8392
- Office of Institutional Diversity and Equity: promote DePaul’s position and
(312) 362-6872 prominence in newspaper, broadcast and
- Human Resources: (312) 362-8500
- Public Safety Office: (312) 362-8400, Web media stories by working with the
(773) 325-7777 media and coordinating interviews,
- Misconduct Reporting Anonymous Hotline:
(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
those governing activities in more
Any employee receiving a subpoena, than one officer’s area of competence
summons, wage garnishment or other and responsibility, those that are
legal request, on behalf of the university for a duration of more than three years,
or individually, must immediately those establishing an exclusive
contact the Office of the General relationship with the other party,
Counsel. The General Counsel’s office and those containing an automatic
handles the release of legal documents renewal provision.
when such requests are appropriately
made. The requests generally require the To review the Contract Requirements and
university to respond within a very short Procedures policy, visit:
period of time. policies.depaul.edu/policy/policy.aspx?pid=81
For policy information, contact the Office Q: Must all contracts be submitted to the
of the General Counsel or visit: Office of General Counsel for legal review?
generalcounsel.depaul.edu
A: No. Most contracts under $50,000 do
Q: What should I do if a government not need to be submitted for a legal
agent requests student or employment review. All special-risk contracts must
records, but does not have be submitted for legal review,
an authorized consent form for regardless of the dollar value.
such records?
Grants and Contract Proposals for
A: Government agents do not always have External Funding
the right to such records and, therefore,
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
organization or agency. For that reason,
Executive officers, academic officers and
proposal submissions must be handled
administrative officers of DePaul, or
by the appropriate departments at
their specific designees, can negotiate
DePaul. The Office of Development is
and execute contracts within their
responsible for providing clearance to
appointed areas of expertise. However,
DePaul faculty and staff to formally
all DePaul employees must follow the
cultivate and solicit private funders. The
university’s Contract Requirements and
Office of Sponsored Programs and
Procedures policy which provides
Research (OSPR) coordinates the
thresholds for negotiation and execution
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: policies.depaul.edu/
policy/policy.aspx?pid=122
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:
ospr.depaul.edu/html/grant/proposal_review_f It is generally inappropriate for any
orm.html member of the faculty or staff to make
gifts or donations in the name of DePaul,
Q: After making a presentation at a to individuals, groups or organizations.
professional conference, a In certain circumstances, however, it
representative from ABC Foundation, a may be in the university’s best interest
private granting agency, requested to make such gifts or the university
that I discuss with them the possibility may take part in a benefit or civic
of submitting a proposal in support of function that requires tickets to be
my project. How should I move purchased. Approval for exceptions to
forward with this request? the general policy must be secured
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
clearance requirements for the ABC For policy information, visit: policies.depaul.
Foundation, and for possible edu/policy/policy.aspx?pid=45
assistance in submitting the request.
To initiate this process go to Q: A member of our department has been
Corporate and Foundation Relations’ battling an illness, and we’d like to
website at giving.depaul.edu/ make a donation to an affiliated
giving/cfr.aspx. charitable organization. Can we use
university funds for the donation?
Q: A colleague of mine is a program
officer with a state agency. She A: University funds cannot be used in
encouraged me to send her a proposal such a way, unless approved by the
for a research project we have been EVP, VP or Dean.
discussing. The deadline is quickly
Honoraria
approaching, so I need to send it to
her by the end of the week. Can I send An honorarium is a payment made to an
her the proposal and copy OSPR? individual, who is not an employee of
the university, for services when payment
A: No. To be eligible for submission, the
of fees is not legally or traditionally
proposal must pass through the review
required. The intent of an honorarium
and approval process coordinated by
payment is to show appreciation for
OSPR. To expedite the process,
participation in university educational,
immediately inform OSPR of the tight
research or public service activities or
deadline and submit your proposal for
events. Payment is limited to guest
review as soon as possible using the
speakers and individuals offering other
Web-based Proposal Review Form
non-commercial services that would not
located at: ospr.depaul.edu/html/grant/
be expected to generate an invoice or
proposal_review_form.html.
formal request for remittance.
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:
policies.depaul.edu/policy/policy.aspx?pid=46
policies.depaul.edu/policy/policy.aspx?pid=283
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.
Athletics
• Recruiting restrictions also extend to
As a Division I member of the National prospective student-athletes’ friends,
Collegiate Athletic Association (NCAA) family and coaches. If a faculty or staff
and the Big EAST Conference, DePaul member encounters a coach or an
University is responsible for compliance Athletic Department staff member with
with the rules both organizations set a prospective student-athlete or family
forth. Some of the most important and member, other than on campus as
sensitive rules include: 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
depaulbluedemons.com/compliance
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
using any images from the university
To maintain a consistent DePaul brand
website or print publications.
and image, the university has several
Unauthorized use of third-party photos
standards for its websites. Web pages
can result in copyright infringement. For
should have a primarily white
questions regarding photos and copyright,
background and the content should be
contact the Director of Enrollment
clear, up to date, and easy to read. All
Communications in Marketing
sites should provide an e-mail link to a
Communications.
webmaster/site manager. Sites must
also include a copyright and disclaimer For website branding information, visit:
line with links at the bottom of the brandresources.depaul.edu
page and links to the DePaul home
For policy information on the Use of EM&M
page on each page. The site’s home
marketing photographs visit:
page should have the Tree of Wisdom
policies.depaul.edu/policy/policy.aspx?pid=277
logo and DePaul signature, and a
DePaul text link. Photo releases may be obtained at:
http://generalcounsel.depaul.edu/Forms/Photo
Any website content that resides on %20Release%20Form.pdf
university servers should be related to
university business and should not A sample photographer agreement may be
obtained at: brandresources.depaul.edu/
contain pornographic or obscene
_downloads/Sample_Contract_Letter.pdf
material, or links to these materials.
D e Paul universit y • CODE OF CONDUCT 8
Q: Are there any restrictions on the use of obtained, information given to third
photos on my website? parties must be limited to present
employment status, current job title
A: No, not as long as the photos are of good and dates of employment.
quality, and you have a signed photo
release form for each person who will Similarly, DePaul carefully maintains
appear on the site. In addition, DePaul and protects all employees’ health
must own the copyright on all photos information, required by the Health
used. Unauthorized use of third-party Insurance Portability and
photos can result in copyright infringement. Accountability Act, or HIPAA.
Photo release forms and other information
Q: I have requested a medical leave and
regarding copyright, are available through
qualify for Short Term Disability (STD).
Enrollment Management and Marketing.
What information is my department
management given on my medical
leave?
CONFIDENTIAL &
SECURE INFORMATION A: The department will receive a notice
indicating the requested leave dates
Confidential information and the approved leave period. To
protect employee health information
DePaul is committed to protecting the
as required under HIPAA and as
privacy of its employees, both during
required by the university’s Health
and after their service at the university.
Information Privacy policy, no
Whether employment information is
information on the medical condition
sought from bona fide agencies, such
of the employee is provided to the
as banks or mortgage companies, or
department.
from potential future employers,
DePaul is careful to release only valid For policy information, visit:
and pertinent information to policies.depaul.edu/policy/policy.aspx?pid=84
appropriate requests.
For policy information, visit:
policies.depaul.edu/policy/policy.aspx?pid=199
Q: I am applying for a mortgage and was
wondering what type of information
DePaul would release about me.
A: The university prefers that all requests
for employee information be made in
writing, ensuring that all requests are
made by bona fide agencies. Employee
authorization should be obtained for
any release of employee information. If
employee authorization is not
D e Paul universit y • CODE OF CONDUCT 9
Family Educational Rights and and full- or part-time status. This
Privacy Act information may be disclosed, unless
the student has specifically requested
A student’s personal information and the information not be released.
academic records are protected under Although DePaul may release directory
the Family Educational Rights and information, the university is aware of
Privacy Act (FERPA). FERPA allows the potential of identity theft and
students to inspect and review their therefore does not disclose this
educational records, amend their information indiscriminately.
educational records when appropriate,
and have control over the disclosure of For policy information, visit:
information from those records. policies.depaul.edu/policy/policy.aspx?pid=281
Educational records contain policies.depaul.edu/policy/policy.aspx?pid=110
information directly related to a
Q: If a student indicates that he or she
student, and are usually maintained by
does not want any information
an educational agency or institution.
disclosed by the university, how should
These records include: files,
the university respond?
documents, and materials in various
mediums such as handwriting, print, A: The university cannot release any
tapes, disks, film or microfiche. information on that individual.
Educational records do not include
“sole possession” notes, law
enforcement unit records, records
exclusively for employees (except for
student employees whose records are
under FERPA), doctor-patient privilege
records and alumni records. Sole
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.
Directory information may be
disclosed by DePaul, as well as other
universities. Directory information
includes the student’s name, addresses
(including e-mail), telephone number,
date of birth, major, year in school,
dates of attendance at the university,
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 e-mail,
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
policies.depaul.edu/policy/policy.aspx?pid=85 copyright and trademark infringement.
Q: While I was on vacation, my supervisor For policy information, visit:
used my computer and accessed some policies.depaul.edu/policy/policy.aspx?pid=116
personal information I have stored on
policies.depaul.edu/policy/policy.aspx?pid=85
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 e-mail at
as necessary in the course of conducting abuse@depaul.edu. 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 affects 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
the software is free for academic use.
A computer password is the first level of
defense in protecting your computer, For more information visit:
electronic files and other data. Many is.depaul.edu/computers/software/index.asp
attacks against computers rely on weak
policies.depaul.edu/policy/policy.aspx?pid=92
passwords based on dictionary words and
birthdates. A better way to protect data is Q: I recently downloaded a pop-up blocker
to create strong passwords for any system 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
is.depaul.edu/security/information_security/Pass policy. Many of the free pop-up blocker
word.asp and anti-spyware downloads available
on the Internet are intended for home
Q: Is it acceptable to share your password or personal use only. Downloading this
when you are in a crunch for time or
type of software in a commercial
will be out of the office?
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.
Adherence to copyright law
Individuals who share their passwords
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
The General Libraries assess fair use and
Help Desk at (312) 362-8765. If the
clear copyright permissions related to
software is not licensed, the Help Desk
library reserves (including electronic
can help you determine whether the
reserves). Faculty posting of copyrighted
software is freeware or if a license must
material on Blackboard and other
be purchased.
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
For policy information, visit:
manufacturer/distributor for
policies.depaul.edu/policy/policy.aspx?pid=263
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 employees, please see the Discovery and
computer network to comply with Copyright policy:
applicable copyright laws. Upon notice policies.depaul.edu/policy/policy.aspx?pid=168
of an alleged copyright infringement or
For more information regarding the appropriate
actual knowledge of an infringement,
use of intellectual property in the academic
DePaul will take all appropriate actions
curriculum, please see the Copyright and Fair
under the Digital Millennium Copyright
Use policy:
Act (DMCA), which may include
policies.depaul.edu/policy/policy.aspx?pid=263
terminating an individual’s access to the
DePaul network. Q: I am a DePaul employee and I have
drafted a training manual for the
For policy information, visit:
university. Am I the copyright owner of
policies.depaul.edu/policy/policy.aspx?pid=83,
this training manual?
or call the Office of the General Counsel.
Reports of alleged copyright infringement
A: Per the Discovery and Copyright policy,
the answer depends on whether an
occurring on DePaul Web pages should be
employee is generally classified as faculty
directed to the university’s designated DMCA
or as staff. In the absence of contractual
agent at abuse@depaul.edu.
provisions obligating the transfer of all or
Q: I would like to download a journal some proprietary rights in a discovery to a
article for use in my classroom. Is this a third party, faculty retain ownership of,
violation of U.S. Copyright laws? and have the right to any income derived
from, copyrighted material that they
A: DePaul has guidelines and resources to conceived or developed. However,
help determine whether such
copyrighted material in which a third-
downloading would be permissible
party contract exists that defines the
under applicable copyright laws.
disposition of copyrights, or in the case of
Intellectual property faculty, resulted from a written work
agreement, or work performed in
DePaul University, in accordance with its accordance with the position of those
academic mission, places the highest value defined as staff, are considered “obligated
on the creation and dissemination of discoveries.” Obligated discoveries are
knowledge, and encourages its employees owned by the university and all of the
to develop and respect intellectual rights to the copyrighted material must
property. Intellectual property includes, be assigned to the university in absence
but is not limited to, copyrightable of a contract to the contrary.
materials, such as scholarly writings,
course materials, films and musical works, Use of university facilities
and inventions such as computer
DePaul has many state-of-the-art and
programs, algorithms, scientific processes,
unique spaces available for student,
and business methods.
faculty and staff use for university-related
For more information regarding the ownership business or activities. This includes
of intellectual property developed by university presentations on academic, professional
D e Paul universit y • CODE OF CONDUCT 13
or administrative development, CONFLICT OF
university business or publicity. INTEREST
Any outside group that wishes to use Outside employment
DePaul’s facilities must pay a fee.
This includes programs that aren’t While DePaul employees are allowed to
meant for a DePaul audience, seek additional work outside of the
but are still reserved by a university university, it should not interfere with
department or member. Events the individual’s time and performance
that charge a registration fee or at DePaul. If there appears to be a
admission to an event must also pay conflict or a performance problem as a
for facility usage. Free use of space is result of outside employment, the
intended to benefit the students, employee may be counseled according
faculty and staff of DePaul. to Human Resource’s Progressive
Discipline policy.
For policy information visit:
policies. depaul.edu/policy/policy.aspx?pid=74 If a faculty member chooses to engage
in outside work, the activities must be
Most university facilities have their own professional in nature and contribute
reservation forms and policies. For a detailed to the development of the faculty
contact guide, visit: studentcenter.depaul. member or provide expertise to the
edu/ConferenceCenter/ConferenceCenter.html community. The time commitment for
-or- such work must not exceed the
studentcenter.depaul.edu/MeetingsandEvents/ equivalent of one day per work week.
LincolnPark.html
A college’s or school’s dean determines
Q: Can I sponsor an off-campus whether a faculty member’s additional
organization that wants to use a activities are within DePaul’s guidelines
DePaul facility for its meeting? on activities outside of the university.
Teaching at another institution while
A: Yes. University departments can sponsor
under contract at DePaul is permitted
events held by off-campus organizations.
only in instances where the dean has
The off-campus organization will need to
given written approval.
pay a fee for use of DePaul spaces. The
sponsoring department may be asked to Q: Could I do occasional work for a family
provide its chart field information for business while I’m employed at
billing purposes and a name of a staff DePaul?
member as a sponsor or contact. For
questions regarding space availability or A: As long as the outside work does not
to make reservations, contact the interfere with or compromise your
Student Center’s administration office. 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
CONDUCT
DePaul requires all employees whose
independence of judgement may be Fraud
impaired by a potential conflict of
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:
policies.depaul.edu/policy/policy.aspx?pid=23 • Misappropriation or misuse of
university resources such as funds,
For the Conflict of Interest Form, visit:
supplies or other assets
financialaffairs.depaul.edu/forms/COI_
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
Department.
of Interest Form, then review it with
your manager and submit it to the Q: Should I confront an individual
Accounts Payable department. suspected of fraud or related
misconduct?
D e Paul universit y • CODE OF CONDUCT 15
A: No. University employees should not Q: My supervisor has recently made
initiate investigations or questioning inappropriate cultural references that I
on their own. All suspected incidents find offensive. I am extremely
of fraudulent or related misconduct uncomfortable with the situation, but
should be reported to Internal Audit. fear that the fall-out from reporting it
would be worse than putting up with
Discriminatory harassment the behavior. What can I do?
DePaul has a long standing commitment A: Report alleged incidents of discrimination
to the diversity of its faculty, staff and to the Office of Institutional Diversity and
student body. The university is committed Equity. The university prohibits retaliation
to preserving an environment that or threat of retaliation in any form
respects the personal rights and dignity of against employees who have filed
each member of its community. It is discrimination complaints in good faith.
DePaul policy that no person shall be the
Sexual harassment
object of discrimination on the basis of
race, color, ethnicity, religion, sex, gender, The learning and work environment
sexual orientation, national origin, should be free from inappropriate
age, marital status, parental status, family conduct of a sexual nature. Sexual
relationship status, physical or mental harassment is illegal and will not be
disability, military status, or any other tolerated at DePaul University. In
status protected by local, state, or accordance with DePaul’s Sexual
federal law in its employment or its Harassment Policy and Procedures,
educational settings. incidents of sexual harassment should
be reported to either a person in a
The Office of Institutional Diversity and
supervisory capacity or to the Office of
Equity is responsible for receiving,
Institutional Diversity and Equity. In
processing and resolving complaints of
addition, all members of the community
discrimination or harassment. All
who serve in a supervisory capacity,
members of the university who serve in
such as deans, managers and
a supervisory capacity, such as deans,
department chairs are responsible for
managers and department chairs, are
reporting all complaints of sexual
responsible for relaying all complaints
harassment to the Office of Institutional
of discrimination or harassment to the
Diversity and Equity. Employees who
Office of Institutional Diversity and
engage in conduct that is prohibited by
Equity. Employees who engage in
the Sexual Harassment policy will be
conduct that is prohibited by the Anti-
subject to disciplinary action, up to, and
Discriminatory Harassment policy will
including, termination.
be subject to disciplinary action, up to
and including, termination. policies.depaul.edu/policy/policy.aspx?pid=119
For more information visit:
policies.depaul.edu/policy/policy.aspx?pid=137
D e Paul universit y • CODE OF CONDUCT 16
Q: During a recent school-sponsored days, should contact the Reed Group
social event held off campus after immediately. Details regarding eligibility
normal work hours, a colleague of criteria and employee rights and
mine made inappropriate statements responsibilities can be found in the
to me of a sexual nature. My university’s Family and Medical Leave Act
colleague’s behavior made me very policy. The university currently uses the
uncomfortable, but it occurred outside Reed Group for administration of FMLA
the workplace after normal work benefits. Questions regarding FMLA
hours. What can I do? should be directed to the Reed Group or
the Office of Human Resources.
A: Work-related events, such as business
travel, or work-sponsored events, even For more information, visit:
if they are held off campus, are policies.depaul.edu/policy/policy.aspx?pid=187
considered extensions of the workplace.
Q: I have been scheduled for a surgical
You should report the incident to your
procedure that will involve a recovery
manager or to the Office of Institutional
period of at least three weeks. How much
Diversity and Equity.
notice do I need to provide my manager?
Family and Medical Leave Act
A: You should inform your manager of
(FMLA)
your plan to be absent as soon as
The Family and Medical Leave Act possible. In addition, you will need to
(FMLA) is a federal law that provides contact the Reed Group to begin the
for leaves of absence for circumstances application process.
that require employees to be absent
Threats and violence
from work for extended periods of time
due to the employee’s serious health DePaul strives to maintain a work
condition, the serious health condition environment free from intimidation,
of an immediate family member (child, threats (direct or implied) or violent
spouse, or parent), the birth of a child, acts. The university will not tolerate
or the placement of a child with an intimidating, threatening or hostile
employee for adoption or foster care. behavior of any kind. Employees who
Under the provisions of the FMLA, engage in conduct that is prohibited by
an eligible employee’s position the Threat Assessment and Reporting
and benefits are protected for up to Policy will be subject to disciplinary
12 weeks of unpaid leave in a rolling action, up to and including
12-month period. termination. As per the Threat
Assessment and Reporting Policy,
Employees are required to supply medical
employees who believe they have been
certification supporting the need for leave
subject to threatening or violent
due to a serious health condition
behavior in the workplace, should
affecting the employee or an immediate
report the incident to their supervisor,
family member. An employee with a
Public Safety or Human Resources.
serious health condition, requiring an
absence for more than three consecutive For more information, visit:
policies.depaul.edu/policy/policy.aspx?pid=219
D e Paul universit y • CODE OF CONDUCT 17
Q: A colleague in my office has developed holiday pay. Supervisors of non-exempt
a reputation for having a bad temper. employees must authorize overtime
Once at a meeting my colleague was before it is worked.
so upset that he threw a stapler across
Questions regarding overtime
the room in a rage. After a recent
compensation should be directed to the
disagreement with him about a work-
Office of Human Resources.
related issue he waited for me in the
lot where I park my car and confronted financialaffairs.depaul.edu/payroll/index.htm
me in an aggressive manner. He said
policies.depaul.edu/policy/policy.aspx?pid=203
that I was “not being fair” and that it
made him “extremely angry.” What policies.depaul.edu/policy/policy.aspx?pid=204
should I do?
policies.depaul.edu/policy/policy.aspx?pid=202
A: DePaul has a no tolerance policy
against intimidating and hostile Q: My supervisor directed me to add five
behavior of this kind. The incident hours that I did not work to my time
should be reported to your manager report as recognition for my contribution
and to the Public Safety Office or to an important project. Is that an
Human Resources. A prompt and acceptable form of recognition?
thorough investigation of the incident
A: No. The time report is an official
will be conducted and appropriate
document that should reflect the actual
action will be taken.
hours worked by the employee.
Overtime and timekeeping Falsification of a time report is a
fraudulent act that is subject to discipline
Non-exempt employees are required to up to and including termination.
complete a time report to receive pay.
Time reports are official records that Employment of relatives
must accurately reflect the time worked.
Relatives of DePaul employees do not
Falsifying a time report is a serious act of
receive preferential consideration for
misconduct that can lead to discipline up
employment at the university. Relatives
to and including termination.
may work in the same department,
DePaul complies with all applicable laws though no individual should be directly
governing wage and hourly supervised by a relative. Additionally,
administration in the workplace. In care should be given to avoid situations
accordance with the Fair Labor where relatives are responsible for
Standards Act (FLSA), non-exempt checking or verifying each other’s work.
employees will receive pay equal to one Relatives are persons related by blood,
and one-half times the regular rate of pay marriage or legal procedure.
for the hours they work in excess of 40
If a conflict occurs, attempts will be
hours in a work week. Overtime is paid
made to find a suitable position within
based on actual time worked, not time
the department or university where one
compensated. Time compensated is time
of the employees may transfer. If no
not worked, such as vacation, sick or
D e Paul universit y • CODE OF CONDUCT 18
accommodations can be made, one of the Employees are encouraged to
employees may be asked to resign. participate in the election process as
long as it is not during the hours they
For more information, visit:
work for the university. However,
policies.depaul.edu/policy/policy.aspx?pid=197
DePaul employees are prohibited from
Q: My new external grant includes funding speaking or acting on behalf of the
for several part-time positions. As university when involved in political
principal investigator and hiring manager, activities. Also prohibited is the use of
I plan to fill one of those positions by DePaul letterhead, university lists,
hiring my daughter. Does the university’s phones or office space to support a
Employment of Relatives policy apply to specific political candidate.
externally funded grant positions too?
When a university-related activity requires
A: Yes. The university’s Employment of contact with a political official, whether
Relatives policy states that no from the City of Chicago, or on state or
individual shall be employed in a federal levels, it should first be cleared
department or unit under the through the Office of Community,
immediate supervision of a relative Government and International Affairs.
regardless of the source of funding.
For policy information, visit:
Political activities and contacts policies.depaul.edu/policy/policy.aspx?pid=117
with public officials policies.depaul.edu/policy/policy.aspx?pid=121
Political participation is a sensitive Q: As I was walking to a building on
issue at DePaul that must be carefully campus, I noticed a sign with a political
understood and followed. The Higher candidate’s name on it in an office
Education Act of 1998 requires window of a DePaul employee. Is this
institutions that receive federal aid to against university policy?
promote voter registration. A “good
faith effort” should be made to A: Yes. The sign could be construed as an
distribute voter registration forms to all endorsement of the candidate named
enrolled students. on the sign by the university. DePaul’s
status as a tax-exempt organization
DePaul is also subject to many political places limits on the types of allowable
limitations due to its non-profit, tax- political activities. In this instance, the
exempt status. For example, the endorsement concern can be alleviated
university or anyone on behalf of the by positioning the sign so it is only
university cannot endorse or fund any visible from the inside of the office.
political activity or individuals running
for public office, whether at the local,
state or federal level. Doing so could
jeopardize DePaul’s tax-exempt status.
D e Paul universit y • CODE OF CONDUCT 19
Environmental health and safety exiting the building, and the assembly
point for your work group after you
DePaul takes the safety and well-being have exited the building.
of the entire university community very
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 publicsafety.depaul.edu/links/index.asp
Environmental Protection Agency’s
Duty to report crime and accidents
(EPA) regulations, other local and state
environmental/safety codes, regulations All crimes committed on or around
and ordinances, and the internal DePaul’s campuses must be reported to
policies of the university. This applies to the appropriate university department
chemical inventory and storage, to ensure that DePaul is in compliance
compilation of Material Safety Data with the Jeanne Clery Disclosure of
Sheets (MSDS), disposal of hazardous Campus Security Policy and Campus
waste, training for employees and Crime Statistics Act, commonly referred
students, and provision of “right-to- to as the Clery Act.
know” information.
DePaul Public Safety officers report all
Environmental, health and safety information felonies and serious misdemeanors to
pertaining to DePaul University can be found at the Chicago Police Department, whether
rmehs.depaul.edu. Hard copies are also or not the victim or person filing the
available from The Office of Risk Management complaint is cooperating with an
and Environmental Health and Safety.
investigation or has a change of mind
For policy information, visit: about reporting a crime. If a victim or
policies.depaul.edu/policy/policy.aspx?pid=60 complainant leaves the scene or refuses
to talk to investigators, Public Safety will
rmehs.depaul.edu/Contribution%20Folder/Docume still file a report with Chicago Police.
nts/Chemical%20Hygiene%20Plan_pdf.pdf
Reporting an accident is just as
rmehs.depaul.edu/Contribution%20Folder/Docu
important as reporting a crime. If an
ments/Waste%20Disposal%20Guide_08_pdf.pdf
accident occurs on university property,
rmehs.depaul.edu/Contribution%20Folder/Docu the Public Safety Department should be
ments/ArtSafey-08.pdf notified so that an accident report will
be issued. If the accident results in an
Q: It is unclear to me what I should do in
injury to a DePaul employee, the Office
the event of a fire or other emergency
of Risk Management should be
that requires evacuating my building.
contacted. If an injury occurs to another
Where do I go to get this information?
person or damages another person’s
A: Your manager can provide you with the property, contact the Office of Risk
evacuation procedures for your work Management.
area. It is important to address the
For policy information, visit:
following areas: the type of alarm or
policies.depaul.edu/policy/policy.aspx?pid=54
announcement, location of emergency
policies.depaul.edu/policy/policy.aspx?pid=105
exits, how to request assistance in
D e Paul universit y • CODE OF CONDUCT 20
Q: I think I’ve been the victim of theft, Q: Our academic department is hosting
what should I do? an event and plans to have food and
alcoholic beverages available to
A: If the crime happens on or to university guests. Can undergraduate students
property, contact the Public Safety enrolled in the program be included on
Department and make sure that a the list of invitees?
Security Report is issued. Then notify the
Office of Risk Management if an
A: Undergraduate students may be
invited to the event. However, the
insurance claim needs to be filed. A copy
event sponsor is responsible for
of the Security Report is needed to
ensuring alcoholic beverages are not
support the insurance claim. DePaul does
served to persons under 21 years of
not provide insurance coverage for
age. Proper controls may include hiring
employee or student personal property. If
a professional bartender to serve
loss of personal property occurs, an
alcohol, on-site security, the presence
employee or student should consult their
of a university representative, a
homeowner’s or renter’s insurance policy.
method of age identification, and
monitoring of the event.
Drug-Free For policy details, go to: policies.depaul.
Workplace and edu/policy/policy.aspx?pid=259
Legal Drinking
Age Compliance
FINANCIAL
As an institution receiving federal financial
MANAGEMENT
assistance, DePaul University complies
with the Drug Free Workplace Act and the Travel and entertainment
Drug Free Schools and Communities Act.
The State of Illinois prohibits the sale, use, The university will reimburse employees
or possession, of alcoholic beverages by and university guests performing services
persons who are under 21 years of age. for the benefit of the university for
Alcohol may be served to those of legal age reasonable business expenses incurred
at university events, including classes. while conducting authorized university
Event sponsors are responsible for having business. Employees are encouraged to use
adequate control measures in place to their university Pro Card for expenses in
ensure that persons under 21 years of age lieu of incurring out-of-pocket expenses.
and persons who are obviously intoxicated When not using a Pro Card, employees are
are not served alcohol. expected to pay expenses out-of-pocket.
All reimbursement requests must be
substantiated by documentation of a
clearly stated business purpose, the
amount of each separate expenditure,
the date of the expenditure, and the
location of the expenditure. An original
D e Paul universit y • CODE OF CONDUCT 21
receipt is required for all As an exception, with the approval of
transactions, except meals of the appropriate Dean or Vice
$25 and under. President, a unit/department may
provide a modest length of
Reimbursement for local travel, generally
service/retirement gift to an employee
considered travel that does not require
in recognition of their years of service
overnight lodging, normally includes
to the university.
trips to non-routine destinations for
business purposes that are not part of In addition, with the approval of the
the normal and usual position appropriate Dean or Vice President,
requirements. Local travel does not a unit/department may send flowers
include normal commuting costs. upon the death of an employee,
DePaul does not reimburse for normal or an immediate family member of
commuting costs. an employee.
For policy information, visit: policies. For policy information, visit: policies.depaul.
depaul.edu/policy/policy.aspx?pid=103 edu/policy/policy.aspx?pid=44
Q: I had to go to a suburban campus for Q: A close family member of an
a meeting. Is my mileage or travel employee just passed away. Can my
expense reimbursable? department purchase a flower
arrangement for the funeral?
A: Yes. As long as the expenses are
not part of your daily travel A: With the approval of the appropriate
or commuting costs, travel expenses Dean or Vice President, a
are reimbursable when visiting unit/department may send flowers
other campuses for business- upon the death of an employee or an
related functions. immediate family member of an
employee. Normally, the cost of the
Gifts from the university flowers should not exceed $150.00. For
memorial donations to outside
In general, university funds are not to
organizations, see the Gifts or
be used to purchase a gift for an
Donations from the University policy.
employee or group of employees.
Any such gifts must be purchased Gift Acceptance and Processing
with personal funds or the
department may take up voluntary All private donations (gifts) received
collections for such purchases. by any area of the university must be
Please note that the university must sent to the Office of Advancement
report and tax, as compensation, all for processing within one working
non-de minimus non-cash gifts it day of receipt of the donation, to
provides to employees. Refer to the ensure the donor receives legal credit
Gifts to Employees policy for and proper acknowledgement.
additional information.
D e Paul universit y • CODE OF CONDUCT 22
If a donor has expressed an intent to Proper use of consultants
give a gift of real or personal
property, securities, a planned gift, or It is expected that university
a gift of $250 or more, the Office of activities will be carried out to the
Advancement must be contacted. maximum extent possible by
Advancement will coordinate an utilizing the services of regular
internal review to determine if the employees. When services required
university can accept the gift and to cannot be provided adequately by
arrange for proper transmission of regular employees within the scope
any accepted gifts to the university. of their university employment,
consultants or independent
Q: Our area would like to solicit private, contractors may be utilized. The
charitable donations in order university is responsible for
to help financially support our analyzing each pay for services
activities. Do we need to obtain situation to determine whether the
university approval? work performed should be treated as
dependent (employee) or inde-
A: Yes. You must obtain approval to
pendent (external consultant/
solicit private, charitable donations
vendor) based on Internal Revenue
that benefit your program from the
Service (IRS) guidelines. The Use
Office of Advancement. You should
of Independent Contractors/
obtain approval from the
Consultants policy provides
Advancement gift officer that works
guidelines to determine dependent
with your area, and you must adhere
versus independent status.
to all existing university solicitation
clearance procedures. Furthermore, if When consultants or independent
you want to conduct a fundraising contractors are necessary, the
event, you must obtain additional Manager of Accounts Payable or the
clearance from the Vice President of Tax Manager should be contacted for
Development via the fundraising aid in determining if the service
event clearance form. The provider should be paid as an
fundraising event clearance form is employee or as an independent
available at alumni.depaul.edu/give/ contractor (external
Forms/FundraisingEvent.aspx. All consultant/vendor) based on Internal
donations you receive must be Revenue Service (IRS) guidelines.
delivered to Advancement Gift
For policy information, visit: policies.
Processing to ensure that donors
depaul.edu/policy/policy.aspx?pid=94
receive legal credit and proper
acknowledgement. policies.depaul.edu/policy/policy.aspx?pid=81
To view the Gift Acceptance and Processing Q: If a current DePaul employee is
policy go to: policies.depaul.edu/ providing services to another
policy/policy.aspx?pid=229
department independent of her
position, should she be paid as an
employee or as a consultant?
D e Paul universit y • CODE OF CONDUCT 23
A: This employee must be paid as an DePaul conducts its business in a
employee and her payment socially responsible manner that
arrangements must be made supports the ideals of its namesake, St.
according to university policies and Vincent de Paul, and his strong beliefs
procedures. If the employee is paid in social justice. The university has a
hourly, there may be overtime Fair Business Practice Committee that
implications. To ensure compliance reviews labor conditions found in
with overtime laws, contact Human factories of DePaul licensees, and
Resources regarding compensation. recommends minimum standards with
which licensees are required to comply.
Trademarks, fair trade and The university expects its licensees to
licensing adopt business practices that are
compatible with these standards.
DePaul owns and controls several
names and logos associated with the For policy information, visit: policies.
university, such as the Tree of Wisdom, depaul.edu/policy/policy.aspx?pid=118
the DePaul signature, Coat of Arms, the
Seal, and the Blue Demons athletic Q: I am ordering a novelty item for my
logo. Any variation or modification to a department event on which I would
DePaul trademarked symbol or logo is like to use a DePaul logo. Who should
illegal, regardless of its intended use. I contact? Do I need to use the
trademark symbol?
To ensure compliance with university
policies and brand standards, contact A: Contact the Director of Sports
the Department of University Marketing and Licensing in Athletics to
Marketing Communications prior to discuss the use of a DePaul logo for
using the Tree of Wisdom or the DePaul your project. The Director will advise
signature on printed materials or you on whether and how to use any
electronic media. Contact the Director DePaul mark and also discuss your next
of Sports Marketing and Licensing for steps for proceeding with the order.
permission prior to using the Blue You must use the trademark symbol,
Demons Athletic logo on any material. even though you plan to give the
The trademark or copyright symbol items away.
(™ or ®) must be used next to DePaul
logos on any item that could be sold,
regardless of whether you intend to
sell it.
D e Paul universit y • CODE OF CONDUCT 24
FINANCIAL AID provisions and any regulations
CODE OF promulgated there under. The
CONDUCT determination of whether conduct of a
DePaul officer, employee or agent falls
within this code shall be made by the
Office of Financial Aid, in consultation
Background
with the Office of the General Counsel. All
DePaul University participates in the questions regarding this code should be
Federal Direct Loan Program and directed to the Office of Financial Aid at
receives Title IV federal loan aid for its (312) 362-8091.
students. As a condition of this
If there is uncertainty as to whether
participation and to comply with the
conduct falls within the restrictions of this
Higher Education Opportunity Act of
code, officers, employees and agents
2008 (HEOA), DePaul has instituted this
must consult with the Associate Vice
Financial Aid Code of Conduct to ensure
President for Financial Aid in advance of
the integrity and compliance of its
proceeding with the conduct. Officers,
administration of student loan programs.
employees and agents subject to this
Though DePaul as a direct lender may
code who receive any of the “gift”
not be subject to every circumstance
exceptions identified in paragraph 2 must
detailed below, the university nonetheless
also report them in writing to the AVP for
prefers to take an expansive approach
Financial Aid.
to combating any actual or appearance
of a conflict of interest with respect Provisions
to student loans.
1. Ban on Revenue Sharing
Procedures DePaul University shall not enter into
any revenue-sharing arrangements
All DePaul University officers, employees
with any lender. This includes any
and agents with responsibilities for
arrangement between DePaul and a
financial aid or student loans must
lender that results in the lender paying a
comply with this code. Such officers,
fee or other benefits (such as a share of
employees and agents must be initially
the profits) to DePaul, its officers,
trained on the code’s requirements.
employees or agents, as a result of the
Thereafter, such officers, employees and
university recommending the lender to
agents shall be annually informed of its
students or their families.
provisions and shall annually certify in
writing their understanding and 2. Ban on Gifts
acceptance of this code. This code will DePaul has a Gifts to Employees Policy
also be attached to the university’s Code (“Gifts Policy”) that outlines guidelines
of Conduct maintained by the Office of and restrictions associated with the
Institutional Compliance. acceptance of gifts offered by third parties
to university employees and business
The Financial Aid Code of Conduct is
units. In addition to the Gifts Policy,
based upon Section 493 of the HEOA and
DePaul officers, employees and agents
shall be interpreted consistently with its
D e Paul universit y • CODE OF CONDUCT 25
employed by the financial aid office or professional development of the officer,
otherwise responsible for education loans employee or agent;
will also be bound by the following gift
• Favorable terms, conditions and
restrictions:
borrower benefits on an education loan
No DePaul officer, employee or agent provided to a student employed by
employed by the financial aid office or DePaul if such terms, conditions or
otherwise responsible for education loans benefits are comparable to those
shall solicit or accept any gift from a provided to all DePaul students;
lender, guarantor or servicer of education
• Entrance and exit counseling services
loans. This ban even applies to gifts
provided to borrowers to meet
whose value falls below the limits of
DePaul’s responsibilities for entrance
DePaul’s Gifts Policy. For the purposes of
and exit counseling as required by
this code, the term “gifts” includes but is
the HEOA, so long as DePaul’s staff
not limited to any cash, gratuity, favor,
controls the counseling and it does not
discount, entertainment, hospitality, loan
promote the products or services of
or other item having a monetary value of
any specific lender;
more than a de minimus amount. The
term as used herein includes a gift • Philanthropic contributions to DePaul
of services, transportation, lodging or from a lender, servicer or guarantor of
meals, whether provided or paid for educational loans that are unrelated to
directly or reimbursed after the expense educational loans or any contribution
has been incurred. from any lender, guarantor or servicer
that is not made in exchange for any
For the purposes of this code, the term
advantage related to education loans; or
“gifts” shall not include any of the items
below. However, officers, employees and • State education grants, scholarships or
agents subject to this code must report financial aid funds administered by or
receipt of any of the following in writing on behalf of a state.
to the Associate Vice President for
Financial Aid: A gift from a lender, guarantor or servicer
of education loans to a family member or
• Standard material, activities or other acquaintance of an individual
programs on issues related to loans or subject to this code is prohibited if (1)
financial information, such as a given with the individual’s knowledge and
brochure, a workshop or training; acquiescence, (2) with reason to believe it
was given because of his or her official
• Food, refreshments, training or
university position. For additional
informational material furnished to an
restrictions on gifts, please refer to
officer, employee or agent of DePaul as
DePaul’s Gifts Policy.
an integral part of a training session that
is designed to improve the service of a 3. Ban on Contracting Arrangements
lender, guarantor or servicer of No DePaul officer, employee or agent
education loans to the institution, if employed in the financial aid office or
such training contributes to the otherwise responsible for education loans
D e Paul universit y • CODE OF CONDUCT 26
shall accept from any lender or its affiliate 7. Ban on Advisory
any fee, payment or other financial Board Compensation
benefit (including the opportunity to No DePaul officer, employee or agent
purchase stock) as compensation for any employed in the financial aid office or
type of consulting arrangement or other otherwise responsible for education loans
contract to provide services to or on who serves on an advisory board,
behalf of a lender, guarantor or servicer commission or group established by
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 shall
on such board, commission or group.
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
5. Ban on Offers of Funds for
conflict or appearance of conflict
Private Loans
between personal and university interests
DePaul shall not request or accept from
exists. In addition to this Conflicts of
any lender any offer of funds to be
Interest Policy, all DePaul officers,
used for private education loans,
employees and agents employed in the
including an opportunity pool loan, to
financial aid office or otherwise
students in exchange for the institution
responsible for education loans are
providing concessions or promises
prohibited from having any conflicts
regarding providing the lender with a
of interest with respect to their respon-
specified number of loans or loan
sibilities for Title IV education loans.
volume, or a preferred lender
arrangement for such loans. In addition to the items above, as a
member of the National Association of
6. Ban on Staffing Assistance
Student Financial Aid Administrators
DePaul shall not request or accept from
(NASFAA), DePaul also follows the
any lender any assistance with call center
standards established in NASFAA’s
staffing or financial aid office staffing.
Statement of Ethical Principles and Code
However, this code shall not be construed
of Conduct for Institutional Financial
to prohibit DePaul from requesting or
Aid Professionals.
accepting assistance from a lender related
to professional development training,
See nasfaa.org/subhomes/MediaCenter/
financial counseling materials (provided
NASFAACodeofConduct.pdf.
they disclose the identity of any lender
that assisted in their preparation) or
short-term, non-recurring staffing during
local, state or federal emergencies.
D e Paul universit y • CODE OF CONDUCT 27
