A.3. Code of Conduct for Employees
The success of Middlebury College depends not only on the competence of its faculty and staff, but also upon its reputation for honesty, integrity, and lack of bias in conducting its affairs. This Code of Conduct identifies basic policy and standards concerning ethical conduct and provides guidance in several areas of specific concern. Each employee of Middlebury College is expected to adhere to these standards of conduct.
Other expectations for Middlebury College faculty and staff are covered in other sections of the Handbook, for example the employee handbook and faculty handbook chapters, and the policies on appropriate use of Web pages and electronic mail in the library and information services chapter.
Middlebury faculty and staff should conduct themselves ethically, honestly, and with integrity in all dealings. They need to be fair and principled in their official interactions and to act in good faith in these matters with others both within and outside the Middlebury community. They should act with due recognition of their position of trust and loyalty with respect to the College and its students, fellow employees, research sponsors, and donors. When in doubt about the propriety of a proposed course of action, they should seek counsel from those colleagues, supervisors, or administrators who can assist in determining the right and appropriate course of conduct.
Proper Use of College Property and Funds
Middlebury faculty and staff must see to it that College resources are not used for other than their intended purposes. College employees have an obligation to manage the institution's resources prudently, with a responsibility to those who provide those resources, including students, parents, alumni, foundations, other donors, and government agencies. Faculty and staff are responsible for safeguarding the tangible and intangible assets of the College that are under their control. College resources may not be converted to personal use, either for oneself or another person. College funds may not be used to make contributions to candidates for public office, to political parties, or to other political organizations that are organized and operated primarily to accept contributions and make expenditures for the purpose of influencing the selection, nomination, election, or appointment of any individual to federal, state, or local public office or office in a political organization, or the election of Presidential electors. College funds may not be used to support defamation.
Accuracy of Records and Reporting
The records, data, and information owned, used, and managed by the College must be accurate and complete. The accuracy and reliability of financial reports is of the utmost importance to the business operations of the College. Faculty and staff must record, allocate, and charge costs accurately and maintain supporting documentation as required by established policies and procedures. All reports, vouchers, bills, invoices, payroll information, personnel records, and other essential business records must be prepared with care and honesty.
Grants and Contracts
Members of the faculty and staff requesting funding from government agencies, corporations, foundations, and other granting organizations have an affirmative obligation to make full, accurate, and honest representations concerning all relevant information submitted to or requested by the granting organization. Accurate and complete records, including supporting documentation as required by the granting organization, of the uses to which grant funds are put must be maintained.
Members of the faculty and staff may be privy to confidential information in the course of their daily work. This information may relate to, among others, students, parents, alumni, donors, employees, and candidates for positions on the faculty or staff. All College employees must safeguard confidential information. This includes ensuring that confidential documents, in either paper or electronic form, are not left unattended; refraining from engaging in discussion of confidential information in forums where the information may be overheard; and protecting the privacy of past and present students, faculty, and staff by maintaining the confidentiality of student and employee records.
Conflicts of Interest
Members of the faculty and staff should avoid improper conflicts of interest that might compromise the integrity and objectivity of the College. Examples of situations involving potential conflicts of interest include working for the College as an outside vendor; using information that the College considers privileged or confidential for the benefit of a person or entity outside the College; utilizing discounts allowed to the College for personal gain; and soliciting for oneself or for a third party anything of value from any person or entity in return for any business or service provided by the College.
Financial conflicts of interest (for example, an employee's participating in the ownership or management of an entity that regularly does business with the College) should be disclosed, reviewed, and appropriately managed or eliminated. No member of the faculty or staff may approve, recommend, or promote a business transaction with a firm in which that person is an officer or senior management employee, or holds more than a 5 percent equity interest, unless such person first discloses in writing the business relationship and the circumstances of the contemplated activity to the Office of the Executive Vice President and Treasurer.
No member of the faculty and staff shall solicit anything of value in return for influencing or exercising his or her discretion in a particular way on a College matter. Faculty and staff should not accept any material gift, gratuity, or other payment, in cash or in kind, from a vendor currently doing business with the College or seeking to do so. Members of the faculty and staff may not solicit or receive discounts or rebates on goods and services offered to them in their private capacity by vendors to the College that exceed those generally available to other customers. Exceptions to this general provision include unsolicited gifts of a nominal value given at holidays, birthdays, weddings, and other commonly recognized social occasions.
Members of the faculty and staff may not improperly collude with other entities, including other colleges and universities, in matters affecting the financial or administrative decisions of the College.
Compliance with Laws and Regulations
Members of the faculty and staff are expected to transact College business in compliance with all federal, state, and local laws and regulations related to their positions and areas of responsibility, including, but not limited to, equal employment opportunity, fair employment practices, and nondiscrimination laws; laws regarding the privacy and confidentiality of employee and student records; and laws regarding workplace safety, workplace policies and regulations, and occupational health. Members of the faculty and staff whose programs operate internationally are expected to comply with the laws of the nations in which those programs operate, including foreign corrupt practices acts.
Obligation to Report Suspected Violations
Faculty and staff are obligated to report suspected violations of these standards promptly to their supervisor, department chair, the associate vice president for Human Resources & Organizational Development, the controller, the dean of the faculty, or the vice president for Finance and Treasurer. Violations in some areas may also be reported through EthicsPoint, a third party provider who ensures anonymous and confidential reporting. Issues of a financial nature, human resources related incidents, workplace safety issues, and copyright infringements can be reported by going to EthicsPoint's website at www.middleburycollege.ethicspoint.com or by calling this toll-free number: 1.866.593.6965. A supervisor or department chair to whom a report of a violation is made is obligated to follow up the report with the appropriate administrative authority. In investigating claims of inappropriate activities, care will be taken to maintain confidentiality. Middlebury College will protect from retaliation anyone who makes a good faith effort to appropriately disclose perceived wrongdoing. However, the College reserves the right to distinguish between retaliation and ongoing performance management related to the "whistleblower." See the College's Whistleblower policy for further elaboration.
Consequences of Violation
Material violations of this code or related College policies and procedures will be considered under the College's established disciplinary practices and procedures for members of the faculty and staff and may carry disciplinary consequences, up to and including dismissal from employment. Such violations may also subject individuals to civil or criminal actions in state or federal courts.
Individuals who supervise others should ensure that their direct reports have received adequate instruction and explanation with respect to their obligations under this code.