Office of Audit Compliance & Ethics Annual Compliance Training 2008-2009

1. Office of Audit Compliance & EthicsAnnual Compliance Training2008-2009 Did you know……. Office of Audit, Compliance & Ethics

2. Compliance – why are we here? • Training – is it worth it? • New Topics • Records Retention & Records Management • General Rules of Conduct • Environmental Compliance • Respect in the Workplace • Reminders and Updates • Code of Conduct • Code of Ethics • Reportline Overview Office of Audit, Compliance & Ethics

3. Basics • Handouts – Going “Green” • Distractions • Cell Phones/Blackberries • Laptops • Questions • Late Entry/Early Exit Office of Audit, Compliance & Ethics

4. Compliance– Why are we here? • Even if you are a long time University employee, there are still policies you may not be familiar with. • “I didn’t know” is not a valid excuse. • Opportunity to hear from you. • Many topics are suggestions from last year’s training. Office of Audit, Compliance & Ethics

5. Training – is it worth it? • More calls to the REPORTLINE during training than any other time of the year. • Advise management on policy concerns as a result of these calls. • Finding more interest in complying with rules because of awareness = less violations. • Important part of an effective Compliance Program. Office of Audit, Compliance & Ethics

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7. RECORDS Office of Audit, Compliance & Ethics

8. Did you know……. Anything you receive, create, or distribute in the course of your job is potentially a state record? Office of Audit, Compliance & Ethics

9. Records Retention • Sections 11-8 and 11-8a of the Connecticut General Statutes • Records Management Liaison Officer (RMLO) • Betsy Pittman, University Archivist University Libraries 486-4507 Office of Audit, Compliance & Ethics

10. Records Retention • State records may only be disposed of after specific retention periods have been met and permission has been received. • Retention Schedules can be found on the Dodd Center’s website: www.lib.uconn.edu/online/research/speclib/ASC/rm/index.htm Office of Audit, Compliance & Ethics

11. Records Retention • What is a state record? • Easier to define what is not a state record. • Examples: • Extra copies kept only for convenience. • Duplicate copies of documents. • Working papers, preliminary drafts, or other material summarized in final or other form and which have no value once action has been taken. Office of Audit, Compliance & Ethics

12. Records Retention – Email • The following types of email may be deleted: • Transitory messages – junk mail; notices; announcements; casual communications. • Other types of email should follow the same retention rules as if they were paper records. • Example – documenting policy or policy process. • Space??? Office of Audit, Compliance & Ethics

13. Records Management Policy The University has recently adopted a Records Management Policy: • Definitions • Procedures • Storage and Transfer Office of Audit, Compliance & Ethics

14. Why is this so important? • Recent security breaches at Universities: • Southern California, Texas, Missouri, Michigan, Ohio State, Nebraska and Stanford. • University of Indianapolis - hackers broke into a server on 9/8/08 and gained access to 11,000 archived records with names and matching Social Security numbers. • Included University President’s. Office of Audit, Compliance & Ethics

15. Did you know……. 90% of records on campus are duplicates? Office of Audit, Compliance & Ethics

16. GENERAL RULES OF CONDUCT Office of Audit, Compliance & Ethics

17. Did you know……. The University’s “General Rules of Conduct” are different than the “Code of Conduct”? Office of Audit, Compliance & Ethics

18. General Rules of Conduct • Most disciplinary hearings involve allegations of violations of the General Rules of Conduct. • The “Rules” often overlap with other University policies and state laws (Code of Ethics). Office of Audit, Compliance & Ethics

19. General Rules of Conduct • Examples: • Interfering in any way with the work of others; • Being inattentive to duty including sleeping on the job; • Behavior that is offensive, abusive or contrary to common decency or morality; • Conviction of a crime. Office of Audit, Compliance & Ethics

20. General Rules of Conduct • A supervisor’s failure to enforce a rule does not excuse an employee from complying with it. • Employees may report suspected violations of the “Rules” to their supervisor, the union, Human Resources, ODE or the REPORTLINE. Office of Audit, Compliance & Ethics

21. Environmental Compliance Office of Audit, Compliance & Ethics

22. What is the UConn Environmental Compliance Office? • Part of the Office of Environmental Policy (OEP). • Assists in compliance with rules and regulations for air & water pollution, wetland impacts and construction. • Leads Environmental Compliance Team (ECT). Office of Audit, Compliance & Ethics

23. Did you know……. In Connecticut, recycling is state law! All public agencies & institutions, … e.g., colleges (UConn), hospitals (UConn Health Center)…must recycle certain items including: • Glass & metal food & beverage containers. • Cardboard, newspaper, white office paper. • Scrap metal & waste oil. • Lead acid batteries (from vehicles). • Ni-Cad rechargeable batteries. • Fluorescent bulbs/mercury containing bulbs. Office of Audit, Compliance & Ethics

24. Have you seen this poster? Office of Audit, Compliance & Ethics

25. Thanks to you, we recycled ~1,000 tons in 2007! 793.8 tons Paper 61.5 tons Bottles/Cans 143.8 tons Cardboard Office of Audit, Compliance & Ethics

26. RESPECT IN THE WORKPLACE Office of Audit, Compliance & Ethics

27. Respect in the Workplace “Something is Happening….” Committee • Membership is across campus and includes labor and management. • Developing recommendations for the administration • Provide Education/Awareness • AFSCME/CEUI Event • UCPEA Event • Poster campaign Office of Audit, Compliance & Ethics

28. Respect in the Workplace Relevant University Policies: • Policy Statement on Harassment • Affirmative Action & EEO • Policy Statement on People with Disabilities • Reasonable Accommodations Policy • Violence in the Workplace Prevention • General Rules of Conduct • Code of Conduct Office of Audit, Compliance & Ethics

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30. Code of Conduct Office of Audit, Compliance & Ethics

31. Code of Conduct Reminder • Core Values – Knowledge, Honesty, Integrity, Respect & Professionalism. • Standards – Education; Research; Patient Care; Campus-Wide; Business, Fiscal and Legal; External Relations and University Advancement. • University policy based on these standards. Office of Audit, Compliance & Ethics

32. State Code of Ethics Update Office of Audit, Compliance & Ethics

33. State Code of Ethics for Public Officials • Intended to prevent individuals from using state position for personal financial benefit. • Office of State Ethics – full investigative and enforcement powers. • Violations may lead to fines and possible criminal charges. Office of Audit, Compliance & Ethics

34. State Code of Ethics - Recent Fines • Retired State Trooper -   Fined $6,000. • Submitted false time cards claiming overtime. • Had already reimbursed the state $7,968.13 • Judicial Branch Employee – Fined $500. • Used state computer equipment, and access to state computer databases, to engage in employment on behalf of an outside employer. • Searched criminal records (public) on personal time. • Maximum penalty at the time was $2,000 Office of Audit, Compliance & Ethics

35. Conflict of Interest: Gifts • Anything of value that is directly and personally received, unless consideration of equal or greater value. • Generally may not accept gifts from “prohibited donors”. • Includes family. • Remember there are exceptions. Office of Audit, Compliance & Ethics

36. Gift Exceptions - New • Major life events - $1,000 limit from registered lobbyist or non-prohibited donor (except for family members). • Birth or adoption of a child • Wedding or civil union • Funeral • Induction into religious adulthood • Retirement STILL is not considered a major life event. Office of Audit, Compliance & Ethics

37. Conflict of Interest: Outside Employment • May not accept outside employment that: • impairs your independence of judgment regarding University duties • encourages you to disclose confidential information. • May not use your state position for financial gain. • May not use state resources (time, materials, personnel) Office of Audit, Compliance & Ethics

38. Outside Employment - NEW • Recent Advisory Opinion regarding the use of supervisors/subordinates in outside employment. • Impermissible for a supervisor or subordinate to employ a supervisor or subordinate in their outside business.  • EXCEPTION: AAUP as long as disclosed on an approved consulting form. Office of Audit, Compliance & Ethics

39. Conflict of Interest: Disclosure - NEW • When a potential conflict of interest exists, Code of Ethics requires employees to prepare a written statement describing the matter and nature of the conflict. • to be given to supervisor. • Supervisor assigns matter to another employee. • Original sent to HR; copies kept by supervisor and employee. • More info to follow. Office of Audit, Compliance & Ethics

40. Conflict of Interest: Appearance Fees/Honorarium • May not personally accept fees/honorarium, if state position was significant factor in being asked. • Payment of necessary expenses is allowed. • Items for which the University would otherwise pay. (does not include entertainment costs or payment of expenses for family or guests. • Reported to OSE within 30 days. (EXCEPTION: FEDERAL OR STATE GOVERNMENT) Office of Audit, Compliance & Ethics

41. Post Employment • Various provisions that may apply after you leave state employment. • NEW – allows sanctions against an entity that hires a former state employee in violation of the post-state employment rules. (PA 08-3) Office of Audit, Compliance & Ethics

42. Reporting Compliance Concerns Office of Audit, Compliance & Ethics

43. Did you know……. “Nearly 60% of state employees witnessed a violation of ethics standards, policy or the law in their workplace within the past year.” -2007 National Government Ethics Survey Office of Audit, Compliance & Ethics

44. Reporting Compliance Concerns • Chain of Command • OACE • REPORTLINE • Phone: 1-888-685-2637 • Web Access: https://www.compliance-helpline.com/uconncares.jsp • State Auditors of Public Accounts Office of Audit, Compliance & Ethics

45. Reporting Compliance Concerns • University policy prohibits retaliation against anyone reporting in good faith a compliance concern to: • Supervisor • Faculty • Administrator • Compliance Office • REPORTLINE Office of Audit, Compliance & Ethics

46. Miscellaneous Reminders • Compliance Courier newsletter • E-Policy website • OACE website Office of Audit, Compliance & Ethics

47. Compliance Training Policy • Formalizes directive from BOT and Federal Government. • University Policy. • Disciplinary action for non-compliance. • Training is required annually (by academic year). • Tell your friends….expect a phone call! Office of Audit, Compliance & Ethics

48. “Resistance is futile, you must comply.” • UCONN Faculty Member Office of Audit, Compliance & Ethics