Office of Audit Compliance

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Office of Audit Compliance EthicsAnnual
Compliance Training2008-2009

• Did you know.

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Overview

• 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

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Basics

• Handouts Going Green
• Distractions
• Cell Phones/Blackberries
• Laptops
• Questions
• Late Entry/Early Exit

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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 didnt know is not a valid excuse.
• Opportunity to hear from you.
• Many topics are suggestions from
  last years training.

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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.

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RECORDS
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Did you know.
Anything you receive, create, or distribute in
the course of your job is potentially a state
record?
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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

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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 Centers website

www.lib.uconn.edu/online/research/speclib/ASC/rm/i
ndex.htm
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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.

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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???

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Records Management Policy

• The University has recently adopted a Records
  Management Policy
• Definitions
• Procedures
• Storage and Transfer

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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 Presidents.

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Did you know.

• 90 of records on campus are duplicates?

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GENERAL RULES OF CONDUCT
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Did you know.

• The Universitys General Rules of Conduct are
  different than the Code of Conduct?

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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).

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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.

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General Rules of Conduct

• A supervisors 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.

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Environmental Compliance
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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).

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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.

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Have you seen this poster?
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• Thanks to you, we recycled
• 1,000 tons in 2007!
• 793.8 tons Paper
• 61.5 tons Bottles/Cans
• 143.8 tons Cardboard

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RESPECT IN THE WORKPLACE
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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

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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

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• Code of Conduct

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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.

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• State Code of Ethics
• Update

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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.

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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

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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.

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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.

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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)

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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.

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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.

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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)

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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)

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Reporting Compliance Concerns
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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

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Reporting Compliance Concerns

• Chain of Command
• OACE
• REPORTLINE
• Phone [phone]
• Web Access
• https//www.compliance-helpline.com/uconncares.jsp
  
• State Auditors of Public Accounts

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Reporting Compliance Concerns

• University policy prohibits retaliation against
  anyone reporting in good faith a compliance
  concern to
• Supervisor
• Faculty
• Administrator
• Compliance Office
• REPORTLINE

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Miscellaneous Reminders

• Compliance Courier newsletter
• E-Policy website
• OACE website

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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!

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• Resistance is futile, you must comply.
• UCONN Faculty Member