C00.0 Code of Ethical Conduct and Compliance

Rochester Institute of Technology shapes the future and improves the world through creativity and innovation.  As an engaged, intellectually curious, and socially conscious community, we leverage the power of technology, the arts, and design for the greater good.  At the heart of this vision and mission is a commitment to excellence that extends to all aspects of our educational and research programs.  In pursuit of excellence, all members of the RIT community are expected to conduct their work in the highest ethical manner and to comply with the law and policies that govern activities and operations of the university. 
   
In that spirit, the Code of Ethical Conduct and Compliance (the “Code”), along with university’s Core Values, Honor Code, Diversity Statement, and Commitment to Environmental Sustainability, provides a framework for acceptable standards of behavior and reinforces the principle that all members of the RIT community, including university officials and the Board of Trustees, have a responsibility to ensure that RIT conducts its business and pursues its mission ethically, legally, and with integrity.  Other university policies provide specific rules and regulations that govern the conduct of university community members, and the Code does not modify the application or enforcement of those policies in any way.

This Code is for the benefit of the entire RIT community.  It applies to all members of the RIT community, including students, faculty, staff, volunteers, contractors, trustees, and other members in the community doing business with or for RIT.  The Code governs all of RIT community members’ conduct while on RIT property, representing RIT, utilizing its resources, or while attending RIT functions.  

All members of the RIT community shall take effective measures to conduct themselves ethically, with integrity, and in compliance with applicable laws and regulations.  The Standards of Ethical Conduct are not an exhaustive list of what RIT community members should and should not do.  The Standards communicate the university's overall expectations of ethical and professional conduct from RIT community members.

1. Respect for Others
   Every member of the RIT community is expected to treat others with respect, civility, and dignity.  Any disrespectful or uncivil behavior falls short of RIT expectations.  RIT prohibits discrimination and harassment and provides equal opportunities for all community members and applicants regardless of  race, religion, age, citizenship, color, creed, culture, including Deaf culture, actual or perceived disabilities, sex, gender, marital status, ethnic or national origin, political affiliation or preference, military or veteran status, sexual orientation, gender identity, gender expression, or genetic predisposition.  All reported claims of discrimination or harassment will be reviewed.  
2. Individual Responsibility and Accountability
   Every member of the RIT community is expected to exercise responsibility appropriate to their position and delegated authorities.  In performance of their roles and responsibilities, members of the RIT community must exercise sound judgment that will further the interests of the university and must be accountable for their actions and decisions. 
3. Fair Dealing
   Each individual member of the RIT community is expected to behave ethically, honestly, and with integrity in all interactions and dealings when conducting RIT business.  This expectation is based on principles of fairness, good faith, and honesty, consistent with laws, regulations, and university policies governing conduct with others both inside and outside the RIT community. 
4. Responsible Conduct of Teaching and Research
   As part of its educational and research mission, RIT is devoted to the pursuit of knowledge and the respectful free exchange of ideas.  RIT is committed to achieving the highest standards of teaching and research, and to conducting these activities with integrity, objectivity, fairness, and in compliance with all applicable laws and regulations.  Members of the RIT community who are pursuing academic research are expected to take this commitment seriously.  First, members of the RIT community must conduct their research with rigor and intellectual honesty and be accountable for sponsors’ funds.  Second, researchers must comply with specific grant and contract requirements as well as RIT policies and procedures regarding research.  Finally, researchers must comply with all federal and state regulations involving research, including the protection and welfare of human and animal research subjects, and obtain appropriate approval and consent for studies involving such subjects.
5. Conflicts of Interest and Commitmen
   The university encourages interactions with external entities that are beneficial to the professional standing of employees, the reputation and mission of the university, or that serve the community or profession at large.  Such interactions may create actual or potential conflicts of interest or commitment.  Members of the RIT community must not let their outside activities or outside financial interests interfere with their obligation to act in the best interest of the university.  All members are expected to apply their time and effort appropriately, to avoid transactions or relationships with vendors that might influence or appear to influence purchasing decisions, or otherwise participate in decisions on behalf of the university if their personal or professional interests directly or indirectly affect or influence the outcome.   
   
   Most actual, potential, or perceived conflicts of interest and commitment can be managed through disclosure and transparency, in accordance with the C04.0 RIT Individual Conflict of Interest and Commitment (ICIC) Policy.
6. Compliance with Applicable Laws, Regulations, and University Policies
   Members of the university community are expected to be familiar with the laws and regulations affecting their areas of responsibility.  Failure to comply can have serious adverse consequences both for individuals and for the university.  University business must be conducted consistently with legal requirements, including contractual commitments undertaken by individuals authorized to bind the university to such commitments.
   
   Many, but not all, legal requirements are embodied in RIT policies and procedures, which are designed to inform our everyday responsibilities, to set minimum standards, and to give the RIT community notice of expectations.  Members of the RIT community are expected to abide by these policies and procedures and to seek clarification on policies or other university directives that may be unclear.  It is not acceptable to disregard RIT policies or procedures if one is not in agreement with them or to avoid compliance by deliberately seeking loopholes.  Additionally, the absence of a policy in any given area does not imply acceptance or endorsement of any particular action or behavior.
7. Business and Financial Recordkeeping and Reporting
   All university accounting and financial records, tax reports, expense reports, time sheets, effort reports, and other documents including those submitted to government agencies must be accurate, clear, and complete. All published financial reports will make full, fair, accurate, timely, and clear disclosures as required under generally accepted accounting principles for government entities, bond covenant agreements, and other requirements.  Accuracy in these tasks will ensure the use of sound business practices by RIT as well as its compliance with applicable laws and regulations and relevant RIT policies and procedures.
8. Stewards of University Resources
   As the recipient of donations, government and private grants, and other contributions, the university strives to be an effective steward of its resources.  Every member of the RIT community is expected to protect and use university resources prudently and only for their intended purposes and consistent with the tax-exempt status of the university.  University assets and resources may include, but are not limited to, university (i) records; (ii) tangible or intangible assets; (iii) intellectual property rights; (iv) computer software, hardware or related technology; (v) rights or claims against third parties; (vi) facilities or real property; (vii) name, logos, or trademarks; and (viii) employees.
9. Community Health and Safety
   RIT is committed to protecting the environment, health, and safety of its community and ensuring the security of university premises and facilities. The university and the RIT community must observe all applicable regulations, standards, and policies and must adhere to sound practices relating to matters of physical safety and environmental health and safety.  Individuals should promptly report any threat or risk to health or safety and should take reasonable steps to promote physical security of themselves and other members of the RIT community.
10. Information Privacy, Confidentiality, and Security
    The university is the custodian of certain confidential, proprietary, and private information.  Individuals who have access to such information are expected to treat this information carefully by observing applicable contracts, laws, and RIT policies and procedures for obtaining, securing, maintaining, handling, divulging, and destroying this information.  All members of the RIT community must limit their use of such information solely to the purpose for which access to the information was granted and consistent with C07.0 Privacy Policy. 
11. Internal Controls 
    Internal controls are the processes employed to help ensure that the university's business is carried out in accordance with this Code, RIT policies and procedures, applicable laws and regulations, and sound business practices. They help to promote efficient operations, accurate financial reporting, protection of assets, and responsible fiscal management. All members of the university community are responsible for internal controls. Each business unit or department head is specifically responsible for ensuring that internal controls are established, properly documented, and maintained for activities for which they are responsible or accountable.  Any individual entrusted with funds, including principal investigators, is responsible for ensuring that adequate internal controls exist over the use and accountability of such funds.
12. Obligation to Report Violations of Law or Policy
    In order to maintain integrity at the highest level of excellence, RIT expects that all members of our university community will report actual or suspected violations of laws, regulations, and policies in a timely manner.  For this reason, RIT prohibits retaliation against any member of the RIT community that reports any such violations.  (See section M, below).   Officers, managers, and supervisors are required to report allegations presented to them or to report suspected violations that come to their attention in the ordinary course of performing their duties.  
    
    Reports of suspected violations of policy or law can be made by: 
    
    Reporting to your immediate supervisor, dean, divisional leader, appropriate university officer.
    
    Reporting to Human Resources at 585-475-2424.
    
    Reporting via the RIT Ethics and Compliance Hotline, which provides university members an anonymous and confidential reporting option 24 hours a day, 365 days a year.  The Hotline can be accessed at by calling (866)294-9358 or (866)294-9572 TTY and/or logging into the online reporting website. The Hotline is not intended to replace or supersede any existing reporting methods or protocols and may not be used to report any health, fire, or safety emergencies.
    
    Contacting the Office of Compliance and Ethics at (585) 475-6111 or by email at complianceandethics@rit.edu.
    
    Additional information about reporting options at RIT can be found at Reporting an Incident. 
    
    To the extent permitted by law, the university will make reasonable efforts to keep confidential the identity of anyone reporting a suspected violation, except if doing so would effectively prevent the university from conducting a full and fair investigation of the allegations.  In addition, the university may make an appropriate disclosure to governmental agencies (including law enforcement authorities).
    
    This Code will be enforced, and RIT will promptly, thoroughly, and impartially investigate all reports of suspected violations to the extent necessary and appropriate by its usual process for any other breach of its policies.  Each member of the RIT community is expected to fully cooperate with investigations, audits, or inquiries undertaken by the university to determine whether this Code, laws, or policies have been violated. Employees may not conduct their own investigations into any alleged misconduct or policy violations, as doing so may compromise the integrity of an investigation and adversely affect both the employees involved and the university.  Reports of suspected violations will be investigated by the appropriate offices tasked with investigating the reported allegation.  RIT may use an internal or external consultant to assist in such investigation. 
    
    If after an investigation RIT determines that a violation of policy occurred, then consistent with other applicable RIT policies and procedures, corrective measures may be taken against any person(s) who was involved in the violation or who allowed violations to occur or persist due to a failure to exercise reasonable diligence.  Corrective actions will be determined on a case-by-case basis.  
13. Protection Against Retaliation
    Retaliation means any adverse action that is taken against or that could discourage a member of the RIT community from reporting actual or suspected misconduct, participating in an inquiry or investigation, or raising a concern.  Corrective action taken as a result of misconduct is not retaliation.  Types of adverse action include, but are not limited to: dismissal from employment; demotion; unfounded negative job references; loss of salary or benefits; transfer or reassignment; denial of promotion that otherwise would have been received; and/or unwarranted written notices.  Adverse action need not be job-related or occur in the workplace to constitute unlawful retaliation (e.g., threats of physical violence outside of work hours).   
    
    Retaliation against any individual who makes a good faith report of suspected violation of this Code, or any other university policy, procedure, law or regulation, or against any individual who participates in an investigation, audit, inquiry, or legal proceeding related thereto is strictly prohibited.  Any member of the RIT community who has been found to have taken retaliatory action against another who reported potential wrongdoing will be subject to discipline.  Likewise, abuse of processes referenced in this policy or other RIT policies, including knowingly making a false report, is also prohibited.   Sections L and M of this policy shall constitute RIT’s Whistleblower Policy.

Responsible Office:
The Office of Compliance & Ethics 

Effective Date:
December 9, 2009 (approved)

Policy History:
August 2011 (edited)
March 25, 2020 (revised)