Maintaining high ethical standards in all dealings with the business community, the public, the College community, and fellow employees is a core value of Scripps College.
Scripps has established a number of policies that are essential to maintaining these standards and 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 address or summarize all College policies. It expresses the general behavioral expectations of employees. Every employee should make him or herself familiar with this expression; moreover, every employee must also comply with all College policies set out in the Scripps Staff Handbook or Faculty Handbook, as appropriate.
All Scripps College employees have an individual responsibility to deal ethically in all aspects of your work and to comply fully with all laws, regulations, and policies. They are expected to assume the responsibility for applying these standards of ethical conduct and for acquainting themselves with the various laws, regulations, and policies applicable to their 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 an employee is ever unsure about the legal course of action, they should immediately request assistance from the Office of the President. However, no one at Scripps College is authorized to instruct employees to engage in any illegal activities under any circumstances.
The College is entrusted with many kinds of confidential, proprietary, and private information about College business dealings and regarding members of the Scripps community. It is imperative that those who have access to this information treat it as strictly classified and 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. Employees are expected to accept responsibility for their 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.
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 breach of conduct and could lead to consequences that affect the employment status of an offender.
Foreign Corrupt Practices
Under the U.S. Foreign Corrupt Practices Act and our policies, employees 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, employees are strictly prohibited from giving domestic governmental officials business gratuities or gifts valued in excess of $50. You should be aware that the U.S. government can and has imposed criminal sanctions on individuals. 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, through employees’ 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 all members of the College’s various stakeholder and constituent groups.
From time to time, Scripps is required to report matters to public or government agencies. Whether or not an employee is directly involved in that process, he or she has 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, employees who are contacted directly about litigation for a governmental investigation should consult their senior staff member immediately.
Our public reports should fairly and accurately reflect the state of our College. If an employee believes the documents do not achieve this, it is the responsibility of that employee to bring the concerns to the attention of the College.
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 an employee’s 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 an employee takes actions or has interests that may make it difficult to perform their work for the College objectively and effectively. A conflict of interest may also arise when an employee, or members of his or her family, receives improper personal benefits as a result of their position with the College, regardless of the source of those benefits. Similarly, employees 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 an employee or a member of his/her immediate family to:
Many times, the best policy is to avoid any direct or indirect business connection with our customers, suppliers, or competitors, except on the College’s behalf. However, if employees think they might have a conflict of interest, they should promptly disclose that conflict to our Treasurer’s Office, regardless of how “natural” or “innocent” the conflict may seem. Through such conversation, we can determine if conflict exists and whether or not it would be appropriate for the employee to proceed despite any conflict, in which case the employee will receive a written authorization from either the treasurer or the president. However, until such written approval is received, employees may not proceed with any “conflict of interest.”
If an employee becomes aware of an unapproved conflict of interest activities on the part of anyone at the College, he or she must report it to the Treasurer’s Office or the Audit Committee of our Board of Trustees.
Use of College Resources
Employees have a responsibility to use College resources, including time, materials, and equipment, for business purposes only. Employees 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. Copyrighted 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:
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 an employee has reason to believe that anyone connected with the College may have or is about to engage in any illegal or unethical behavior, or has otherwise violated this Code, he or she should promptly bring the matter to the attention of the president or treasurer. If the employee does not believe that talking to the president or treasurer is appropriate, or if it does not result in a comfortable or appropriate response, the employee should contact any of the College’s other senior officers or any member of the Audit Committee of our Board of Trustees. Employees should not accept any direction by their supervisor that contradicts these policies. If asked, the College we will keep employees’ names 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.
The College will not tolerate retaliation of any kind against any person who in good faith reports potential 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
Employees are responsible for ensuring that their 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 involved employees to civil or criminal charges and penalties.
If an employee is unsure about whether some action or situation would be consistent with this Code of Business Ethics, or if he or she encounters a situation and is unsure about what to do, the employee agrees to discuss it with their supervisor or an officer of the College before taking further action.