Policy 090.00 UMGC Contractor Code of Ethics

Originator: Office of Legal Affairs

Subject: UMGC Contractor Code of Ethics

1. Purpose

   As a federal contractor, University of Maryland Global Campus (UMGC) must maintain high ethical standards and comply with all applicable laws, rules, and regulations. Adherence to this Code is required for UMGC as a federal contractor in accordance with Federal Acquisition Regulation (FAR) 52.203-13 Contractor Code of Business Ethics and Conduct.

2. Definitions

   1. Code: The Contractor Code of Ethics.
   2. Compliance Program: UMGC's written procedures and practices that are designed to ensure all employees are aware of its Contractor Code of Ethics and adhere to its standards.
   3. Employee: Any person employed by UMGC, including all faculty and staff, regardless of division or employment status.
   4. Overseas Employee Code of Conduct: The Code of Conduct that applies to all employees assigned to or visiting UMGC's overseas divisions (both in Asia and Europe). This Code of Conduct is available on the overseas divisions' intranet sites and copies can be received by contacting the Office of the Senior Vice President for Overseas Operations.

3. Employee Obligations Under the Code

   Employees must comply with this Code and if they do not, they may be subject to disciplinary action, up to and including termination of their employment with UMGC. Specific Obligations all employees have under this Code include the following:

   1. Duty to Report: All employees have a duty to report all suspected violations of the Code or other potentially unethical behavior by anyone, including other employees and contractors. Reports may be made to UMGC's Office of Legal Affairs at legal-affairs@umgc.edu. Anonymous reports may be made to USM's Office of Internal Audit Fraud Hotline.
   2. Compliance with Laws: All employees are required to follow all federal, state and local laws applicable to them during their employment with UMGC. This includes, but is not limited to, criminal laws regarding fraud, conflicts of interest, and bribery.
   3. Discrimination/Harassment Prevention & Elimination: UMGC's Policy and Procedures on Affirmative Action, Equal Opportunity and Sexual Harassment was established to prevent or eliminate discrimination and/or harassment in accordance with due process while protecting the rights of our students, faculty, and staff. Under this Policy and Procedures, employees are required to fully cooperate with any investigations of alleged discrimination and/or harassment. If an employee fails to do so or provides false information during an investigation, the employee may be subject to disciplinary action, up to and including termination of employment. See UMGC Policy VI-1.00 - Non-Discrimination and Anti-Harassment.
   4. Drug-Free Workplace: All UMGC employees are subject to the University System of Maryland's Policy on a Drug-Free Workplace. In accordance with this Policy, UMGC's workplace should be free from the illegal possession or distribution of controlled substances. In addition to any legal penalties that may be applicable to employees, they will also be subject to disciplinary action if they violate USM's Policy on a Drug-Free Workplace.
   5. Conflicts of Interest: Employees are obligated to avoid situations and activities which could conflict with their employment at UMGC. Employees must also comply with the Maryland Public Ethics Act. This includes the following:
      1. An employee may not participate in a matter involving a company or other business entity in which he or she or certain relatives (spouse, father, mother, sister, brother, or child) have a legal or financial ownership interest.
      2. An employee may not participate in a matter involving a company or other business entity in which he or she or certain relatives (spouse, father, mother, sister, brother, or child) are employed or may be employed.
      3. An employee may not have a financial interest in, or be employed by, an entity having or negotiating a contract with UMGC. This includes serving on a private board of directors, even if there is no compensation for this service.
      4. An employee may not hold any secondary employment relationship that would impair the employee’s impartiality and independence of judgment.
      5. An employee may not intentionally use the prestige of his/her employment or of UMGC for his/her own private gain.
      6. Miscellaneous unsolicited gifts of a nominal value, not including cash and gift cards, may be accepted by employees. However, an employee may not solicit gifts and may not knowingly accept any gift, directory or indirectly, if it would result in an actual or a perceived conflict of interest. This could be when the gift is from any person whom the employee knows or has reason to know:
         1. 1. is doing or seeking to business of any kind with UMGC,
            2. is engaged in activities that are controlled by UMGC,
            3. has financial interests that may be substantially affected in a specific way by the employee, or
            4. is a lobbyist with respect to the matters within UMGC's functional jurisdiction.
      7. An employee may not disclose confidential information acquired during his/her employment for his/her own or another's economic benefit.
   6. Confidentiality: Employees may require access to confidential, personal information in order to perform their job duties. This information may include confidential student and/or employee records and other documents which contain personally identifiable information (PII), collectively referred to as "Confidential Information". With respect to Confidential Information, employees have the following obligations:
      1. Employees shall ensure that they comply with all  applicable UMGC and USM policies, procedures, and practices concerning the  confidentiality of records and PII.  This  includes UMGC's overseas divisions are also obligated to abide by this Code of Conduct.
      2. Supervisory Employees: In addition to the obligations already stated in this Code, supervisory employees:
         1. Shall ensure that the employees they supervise are acting in a manner consistent with this Code, and
         2. Shall not direct the employees they supervise to  participate in, approve or tolerate any violation of any provision of this Code.

   7. Additional Information About Code
      For additional information about this Code, please contact the Office of Legal Affairs at legal-affairs@umgc.edu