Director Level and Above Code of Business Ethics
Scripps College prides itself on maintaining high ethical standards in all dealings with the business community, the public, the College community, and fellow employees. Scripps has certain policies essential to maintaining these standards – Scripps College Mission Statement, Principles of Community and the Guide to Student Life. All of those who work for Scripps College are aware of our commitment to these standards, and we will work hard to meet them. However, to formalize our commitment to certain critical policies, our Board of Trustees has adopted a Code of Business Ethics.
This Code of Business Ethics does not summarize all our policies. Every employee must also comply with all of our other policies set out in our Staff Handbook or Faculty Handbook, as appropriate.
Please read this statement carefully and then sign it where indicated if you understand and agree to it.
- Individual responsibility. As a Scripps College employee, you have an individual responsibility to deal ethically in all aspects of your work and to comply fully with all laws, regulations, and policies. You are expected to assume the responsibility for applying these standards of ethical conduct and for acquainting yourself with the various laws, regulations, and policies applicable to your assigned duties. College administration, 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. If you are ever unsure about the legal course of action, please immediately request assistance from the Office of the President. However, no one at Scripps College is authorized to instruct you to engage in any illegal activities under any circumstances.
- Confidentiality.The College is entrusted with many kinds of confidential, proprietary, and private information regarding members of the Scripps community, the College, and its business dealings. 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.Records containing personal data on employees and students are confidential. They are to be carefully safeguarded and kept current, relevant, and accurate. They should be disclosed only to authorized personnel having a “need to know” or pursuant to lawful process as approved by the Office of Human Resources.
- Honesty and fairness. Scripps College expects from each of its employees honesty and fairness in dealing with others. You are expected to accept responsibility for your actions and to report information accurately to fellow employees and supervisors. Supervisors have a responsibility to set examples of honesty and fairness in their relationships with their employees.
- College Records. All College records and other essential data must be prepared accurately. Preparing an intentionally false or misleading report or record of measurement is considered a serious offense.
- Foreign Corrupt Practices. Under the U.S. Foreign Corrupt Practices Act and our policies, you are strictly prohibited from giving anything of value, directly or indirectly, to foreign government officials or foreign political candidates in order to obtain or retain business or financial advantage. In addition, you are strictly prohibited from giving domestic governmental officials business gratuities or gifts valued in excess of $50.00. You should be aware that the U.S. government can and has imposed criminal sanctions on individuals and entities that have improperly given gifts to U.S. government personnel, and the promise, offer, or delivery to an official or employee of the U.S. government of a gift or other gratuity would not only violate our policies, but might also be a criminal offense.
- Honesty and Fair Dealing. Scripps College seeks to meet its goals honestly and fairly, and we seek advantages through superior performance, hard work, and intellectual skill. We believe that strong competition is the cornerstone of our economy and that unethical or illegal business practices have no part in this competition. We strive in all instances to deal fairly with our customers, suppliers, competitors, officers, employees, and students and their families.
- Reporting Requirements.From time to time, Scripps is required to report matters to public or government agencies. Whether or not you are directly involved in that process, you have several responsibilities:
- Depending upon your position, the College may ask you to provide information to ensure that our reports are complete, fair, and understandable. We expect you to provide prompt, accurate answers to inquiries related to our public disclosure requirements.
- All College accounts, financial reports, tax returns, expense reimbursements, time sheets, and other documents, including those submitted to government agencies, must be accurate, clear, and complete. All entries in College books and records, including departmental accounts and individual expense reports, must accurately reflect each transaction. Our books, records, accounts, and financial statements must conform to generally accepted accounting principles, to applicable legal requirements, and to the College’s system of internal controls. Any funds or assets under College control must be recorded in the books of account. Additionally, records should always be retained or destroyed consistent with our current record retention practices. In accordance with our policies, in the event of litigation of governmental investigation, please consult one of the officers of the College immediately.
- Our public reports should fairly and accurately reflect the state of our College. If you believe they do not, you have a responsibility to bring your concerns to our attention.
Because of the importance of this issue, the Audit Committee of our Board of Trustees has adopted a policy that requires every employee of Scripps College who has any concerns about the manner in which the College’s financial statements or public reports are prepared, the sufficiency of its internal financial controls, the honesty or competence of its financial management or independent auditors, or any other matter within the purview of the Audit Committee to report the matter promptly to any member of the Audit Committee. The policy states that “the Audit Committee will attempt to keep the name of the person reporting the potential issue confidential to the extent requested by that person and not inconsistent with the best interests of the College. The Audit Committee will not tolerate retaliation against any person who reports potential issues to the Audit Committee in good faith.”
- Conflict of Interest.Each employee should be sensitive to situations that could raise questions of potential or apparent conflicts between personal interests and the College’s interests. A “conflict of interest” exists whenever your private interests interfere or conflict in any way (or even appear to interfere or conflict) with the College’s interests. A conflict of interest can arise when you take actions or have interests that may make it difficult to perform your work for the College objectively and effectively. A conflict of interest may also arise when you, or members of your family, receive improper personal benefits as a result of your position with us, regardless of the source of those benefits. Similarly, you owe Scripps College a duty to advance its legitimate interests when the opportunity to do so arises.As examples, it is a conflict of interest for you or a member of your immediate family to:
- receive any form of compensation from any person with whom the College is doing business;accept gifts of significant value from any person with whom the College is doing business;own an interest in any supplier to the College (other than an interest of less than 1% in a public company);
- take personally business opportunities that properly belong to Scripps College discovered through the use of its tangible or intangible property, confidential information, or your position with it;
- use the College’s tangible or intangible property, confidential information, or your position with the College for personal gain; or
- compete with the College (this provision in no way is meant to preclude family-member employment at another institution of higher education).
Many times, the best policy will be to avoid any direct or indirect business connection with our customers, suppliers, or competitors, except on our behalf. However, if you think you might have a conflict of interest, you should promptly disclose that conflict to our Treasurer’s Office, regardless of how “natural” or “innocent” the conflict may seem. In that way, we can determine whether we believe that you can proceed despite any conflict, in which case you will receive a written authorization from either the Treasurer or the President. However, until you receive such a written approval from one of them, you may not proceed with any “conflict of interest.”
If you become aware of an unapproved conflict of interest on the part of anyone at the College, you must report it to the Treasurer’s Office or the Audit Committee of our Board of Trustees.
- Use of College Resources. You have a responsibility to use College resources, including time, materials, and equipment, for business purposes only. You may not use College property (such as grounds, building or office equipment, computers, tools, materials, assets, and facilities) for anything other than College purposes, unless authorized by the President or Treasurer or consistent with the “Scripps and The Claremont Colleges General Computer Guidelines”. College property shall not be sold, loaned, given away, intentionally damaged, destroyed, or otherwise disposed of, regardless of condition or value, without proper authorization. Copyright material (including books, articles, computer software programs and tapes) should not be infringed.Scripps College is a nonprofit organization under the Internal Revenue Code. As a nonprofit, the College receives donations from a wide variety of individuals, corporations, and foundations. All College personnel have a responsibility to use such funds prudently, ethically, and for the purposes for which they are designated. In order to honor donors’ intentions—and to protect the College’s not-for-profit status—employees and student organizations using student activity fees and/or profits from College-related student-operated business may not:
- make donations with College funds or assets to other nonprofit and/or charitable organizations;
- use College funds (from budgets, student fee allocations, “profits” from College-sponsored, student-operated businesses) for fund-raising purposes for other nonprofits/charities.
Scripps enthusiastically encourages its employees to directly support charities or organizations of their own choice. However, employees should not engage in fund raising for other nonprofit and/or charitable organizations during business hours.
The Claremont Colleges, including Scripps, have historically supported the efforts of both Ox-Fam and SOVA Food Drive by permitting students to “donate” the value of dining hall meals from the board plan under specific program guidelines. This support will continue.
- Reporting any Illegal or Unethical Behavior. If you ever think that anyone connected with the College may have taken, or is about to take, any illegal or unethical behavior, or has otherwise violated this Code, you should promptly bring the matter to the attention of our President or Treasurer. If you do not believe that talking to the President or Treasurer is appropriate, or if it does not result in a response with which you are comfortable, then you should contact any of the College’s other officers or any member of the Audit Committee of our Board of Trustees. You should not accept any direction by your supervisor that contradicts these policies. If you ask, we will keep your name confidential unless this would violate applicable law or our responsibilities to others.
- Special Requirements for Consent or Waiver. Any consent or waiver with respect to this Code must be in writing and approved by a majority of the Board or its authorized committee.
- No Retaliation. The College will not tolerate retaliation of any kind against any person who in good faith reports to us potential issues relating to violations of law or this Code by another party or parties. Raising such concerns is a service to the College and will not jeopardize anyone’s employment.
- Consequences of Violations of Scripps’ Policies. You are responsible for ensuring that your own conduct and the conduct of anyone reporting to you fully comply with this Code and with Scripps’ policies. Violations will result in the taking of appropriate disciplinary action up to and including discharge from employment. Disciplinary action will be taken in accordance with the procedures applicable to faculty or staff, as the case may be. Conduct representing a violation of this Code may, in some circumstances, also subject you to civil or criminal charges and penalties.
If you are ever unsure about whether some action or situation would be consistent with this Code of Business Ethics, or if you encounter a situation and you are unsure what to do, you agree to discuss it with your supervisor or an officer of the College before taking further action.