TSU Office of Institutional Compliance

Code of Conduct for Grants Management and Contract Services

SUMMARY: The purpose of this Code is to establish basic principles, which govern the University’s Grants Management and Contract Services business dealings. Section headings are:

1. BACKGROUND

One of the keystones of the Texas Southern University’s success has been integrity in its dealings with people both inside and outside the University. The University is in a position of trust with many external organizations and agencies. Ethical conduct has been and continues to be the foundation of our success.

TSU strives to comply with pertinent laws, regulations, statutes, policies and procedures. The University recognizes the federal government is a source of funds for the University and dealings with the government impose additional responsibilities. University administrators, deans and directors are expected to assume personal responsibility and accountability for knowledge and understanding of relevant laws and regulations that govern Grants Management and Contract Services, and ensuring compliance. Furthermore, principal investigators and faculty members have a duty to oversee employee compliance and take appropriate disciplinary action for acts of non-compliance.

2. GENERAL RESPONSIBILITIES

Individual Responsibility – Ethics and integrity are the responsibility of each employee. Each member of the faculty and staff, as well as any other person acting on behalf of the University, is responsible for ethical conduct consistent with this Code and with the University's Ethics Policy. University administrators, department heads and others in supervisory positions must assume responsibility for ensuring that their conduct and the conduct of those they supervise complies with this Code.

Business Activities – Business activities undertaken on behalf of TSU must reflect the highest standards of honesty, integrity and fairness. Every employee must be careful to avoid the appearance of misconduct or impropriety.

3. COMPLIANCE WITH LAWS, GRANTS AND CONTRACT OBLIGATIONS

TSU employees are expected to transact business in compliance with the laws and regulations of the State of Texas and any other jurisdictions in which the University does business. In instances where laws and regulations are difficult to interpret or apply, TSU employees should contact the Office of the General Counsel for interpretation.

In addition to laws and regulations, TSU takes grants management and contractual obligations to donors, the state or federal government, external agencies and suppliers very seriously. TSU employees are expected to adhere to relevant contracts and grants requirements and fulfill obligations. In instances where particular contractual or grant requirements are difficult to interpret or apply, TSU personnel should consult with the appropriate administrative official or direct inquiry to the Office of Institutional Compliance.

4. COMPLIANCE WITH STANDARDS OF INTEGRITY

TSU recognizes that it must earn and maintain a reputation for integrity that includes, but is not limited to, compliance with laws and regulations and its contractual obligations. Even the appearance of misconduct or impropriety can be damaging to the University. Frequently, TSU’s business activities are not subject to specific laws or regulations but as implied. In these instances, rules of fairness, honesty, and respect for the rights of others shall govern our conduct.

TSU employees should strive to conduct University business transactions with the utmost honesty, accuracy, and fairness. Each situation needs to be examined, and under no circumstance should an unethical practice be resorted to on the grounds that it is “customary”, either inside or outside of TSU. Expediency should never compromise integrity.

5. CONFIDENTIAL INFORMATION

The University is entrusted with many kinds of confidential, propriety and private information. It is imperative that those who have access to this information do not make any unauthorized disclosures of the information, either during or after employment. If concerns exist regarding the release of confidential information, the Office of Human Resources or Office of General Counsel should be contacted.

6. PROPER RECORDING, ALLOCATION AND CHARGING OF COSTS

Appropriate Accounts – Care should be taken to ensure proper recording and charging of costs to the appropriate account. It is important that costs are accurately recorded so that only allowable direct and indirect costs are charged to the government. If there are any questions about proper treatment of costs, contact the Office of Contract and Grants or the Office of Institutional Compliance.

Reasonable and Allowable Costs – Reimbursement from the government shall be requested only for costs that are reasonable in amount and are allowable under government regulations. Questions relating to reasonableness, allowability and allocability of costs should be directed to the Office of Contract and Grants or the Office of Institutional Compliance.

Financial Reporting - All University accounts, financial reports, tax returns, expense requirements, time sheets, and other documents (including those submitted to government agencies) should be clear, accurate and complete. All entries in University books and records, including departmental accounts and individual expense reports, must accurately reflect transactions and have supporting information.

7. CONFLICT OF INTEREST

Employees should be sensitive to situations that could raise questions of potential or apparent conflicts between personal interests and the University’s interests. As part of the TSU community, each of us should conduct ourselves accordingly. We must be particularly aware of situations where there exists a conflict between the private interests and the official University responsibilities of an employee.

8. GRATUITIES AND "KICKBACKS"

Government Officials – TSU personnel shall not give, offer, or promise anything of value to any government official to enhance relations with that official or the government, regardless of whether that official is in a position to influence any government decision with respect to TSU or its activities. This includes, but is not limited to, entertainment, meals, refreshments, gratuities, or gifts. Employees should consult the TSU Ethics policy for guidance in this area.

Contractors and Others – TSU personnel shall not give, offer, or promise anything of value to any prime contractor, subcontractor, or other for the purpose of improperly obtaining or receiving favorable treatment. Nor shall any TSU personnel solicit or accept anything of value from any prime contractor, subcontractor or other for such a purpose.

9. REPORTING OF VIOLATIONS

Reporting to Management – Employees should report any suspected violations of applicable laws, regulations, statutes, policies and procedures, or this Code. Reporting of suspected violations should be made through standard management channels, beginning with immediate supervisor and progressing to higher levels of management. In the event, other reporting avenues are desired, employees may report suspected violations to the Office of Institutional Compliance or Office of Internal Audit or Office of General Counsel.

Confidentiality – Reports may be made confidentially to the extent permissible by law and should include a detailed description of the alleged violation, applicable dates, reference to supporting evidence or documentation, name of contact person and phone number. The more information given the easier it is to investigate the alleged violation.

Employees should be aware that raising concerns is a service to the University and will not jeopardize employment. In addition, all employees are expected to cooperate fully in the investigation of any misconduct.

10. CONSEQUENCES OF VIOLATIONS

Each employee is responsible for ensuring that his or her conduct, as well as the conduct of his or her staff complies with this Code, applicable laws, regulations, policies and procedures. Violations may result in appropriate disciplinary actions, up to and including discharge from employment. Disciplinary action will be taken in accordance with University policy. In addition, employee conduct that is a violation to laws may, in some instances, also subject an individual to civil or criminal charges and penalties.