University Policies › Administrative and Governance › Code of Business Ethics and Conduct

Code of Business Ethics and Conduct

POLICY TITLE:	Carnegie Mellon University Policy on Code of Business Ethics and Conduct
DATE OF ISSUANCE:	This policy was approved by the President’s Council on October 26, 2010. Administrative changes were approved on July 14, 2023.
ACCOUNTABLE DEPARTMENT/UNIT:	Questions regarding the intent or applicability of the individual policies referenced in this Code should be directed to the person responsible for each policy. General questions about this Code may be addressed to the Vice President and General Counsel, 412-268-3662.

Authority

Carnegie Mellon University has various well-established policies, principles, procedures, and guidelines (some of which are referenced throughout this Code of Business Ethics and Conduct) which apply to different aspects of the University’s business and operations. As a result of the enactment and/or issuance of various laws, regulations and/or other legal, contractual, or proposal requirements, it is necessary to re-state some of these various policies, principles, procedures, and guidelines into one Code of Business Ethics and Conduct. This Code is updated periodically to account for new or updated University policies, principles, procedures, and guidelines and/or new or updated laws, regulations and/or other legal, contractual, or proposal requirements.

Applicability

This Code applies to faculty and staff. This Code also applies to students when working for the University or when otherwise participating (or when proposed or expected to participate) in a sponsored project. These individuals are referred to in this Code as “members of the University community.”^[1]

Introduction and Purpose

The University’s mission to create and disseminate knowledge and art through research and creative inquiry, teaching, and learning requires all members of the University community to maintain the highest ethical and professional standards in all domains. Accordingly, all members of the University community subject to the Code are expected to honor this Code.

This Code reflects the University’s well-established policies, principles, procedures, and guidelines governing the behavior of all members of the University community subject to the Code, and is intended to function as a useful summary of ethical principles and to emphasize the importance of observing these principles. As such, this Code draws on the ethical and behavioral standards set forth in many separate University policies, principles, procedures, and guidelines as well as applicable laws and regulations. This Code supplements but does not supplant other applicable University policies, principles, procedures, and guidelines including, but not limited to, official University Policies, the Faculty Handbook, the Staff Handbook, the Word, and guidelines issued by the University’s Office of the Vice President for Research (OVPR) and/or its Office of Research Integrity and Compliance (ORIC).

Code of Business Ethics and Conduct

Ethical and Professional Conduct. All members of the University community are expected to observe the highest standards of ethical and professional conduct, and to conduct all business and related professional activities in good faith and with fairness, accuracy, integrity and respect for others. The foregoing includes the requirement for all members of the University community engaged in research activities to engage in the responsible conduct of research, and prohibits those members from engaging in research misconduct, including fabrication, falsification or plagiarism in proposing, performing or reviewing research, or in reporting research results.

All members of the University community are also expected to act with due recognition of their position of trust and loyalty with respect to the University, and its students, research sponsors and donors. When in doubt about the propriety of a proposed course of action, a member of the University community should seek counsel from colleagues, supervisors or University administrators who can assist in determining the right and appropriate course. Existing University policies, principles, and guidelines on ethical and professional conduct include without limitation:
Respect for Others. The University embraces diversity as a core value and is committed to establishing a campus culture that reflects a fundamental respect for different ways of living, working and learning. The University also is committed to the principle of non-discrimination, and does not tolerate discrimination or harassment on the basis of race, color, national origin, sex, handicap, religion, creed, ancestry, belief, age, veteran status, sexual orientation or gender identity. Existing University policies, principles, and guidelines involving respect for others include without limitation:
Conflicts of Interest and Commitment and Research Disclosures. A conflict of interest occurs when a member of the University community is in a position to influence a decision where such member might directly or indirectly receive a financial and/or other benefit or give improper advantage to associates. A conflict of commitment arises when a member of the University community's involvement in outside activities substantially interferes with such member’s commitment to the University. All members of the University community should use good judgment, professional commitment and ethics to protect themselves and the University from potential conflicts of interest or commitment. In order to support the University’s research compliance program, members of the University community must make disclosures of conflicts of interest, conflicts of commitment, financial interests, and/or other outside activities (which could include, but not necessarily limited to, disclosures related to information in biographical sketches and/or current and pending (other) support) as and when required by University’s OVPR and/or its ORIC. Consistent with University policies, members of the University community should also discuss and document any potential conflict of interest or commitment with the member’s supervisor or University administrators who can assist in determining the right and appropriate course. The disclosure by a member of the University community to the member’s supervisor or University administrators should occur even if the matter was required to be disclosed to the University’s OVPR and/or its ORIC. Existing University policies, principles, and guidelines involving conflicts of interest and commitment and/or research disclosures include without limitation:
Compliance with Laws and Regulations. The University is subject to numerous laws and regulations that govern the various activities of the University as an employer, government contractor and institution of higher education. All members of the University community are expected to familiarize themselves with the federal, state and local laws and regulations that apply to their activities and conduct themselves in compliance with such laws and regulations. Noncompliance, even when inadvertent, can have severe consequences to the members involved and the University, including, but not limited to, civil liability, loss of funding, reputational harm and, in extreme cases, criminal prosecution or sanctions. Questions about the interpretation or applicability of law or regulations should be directed to the University's Office of the General Counsel.
Compliance with Policies, Procedures, and Guidelines. All members of the University community are expected to familiarize themselves with and follow applicable University policies, procedures, and guidelines. As part of this, each member of the University community also is expected to follow the policies, procedures, and guidelines enacted by the academic or administrative unit within which the member is working at the University. Questions about a specific policy, procedure, or guideline should be directed to the individual or office responsible for oversight of that policy, procedure, or guideline. Existing University policies, procedures, and guidelines include without limitation:
Authority to Commit the University and Compliance with Agreements. In the ordinary course of its business of education and research, the University enters into various agreements, such as contracts, grants, licenses, gifts, purchase orders and other binding obligations, from federal and non-federal sources. Entering into an agreement by the University, including sponsored research funding, creates a legal obligation on the part of the University to comply with the terms and conditions of that agreement, including applicable laws and regulations. Therefore, only individuals who have authority delegated by an appropriate University official are authorized to enter into agreements on behalf of the University.

All members of the University community are expected to act in good faith and adhere to all agreements and other binding obligations undertaken by the University. In particular, members of the University community involved in sponsored research activities must strictly adhere to all contractual obligations (including adhering to applicable laws and regulations) related to those activities. Existing University policies, principles, and guidelines involving authority to commit the University and compliance with agreements include without limitation:
Appropriate Treatment of Confidential and Private Information. Members of the University community may have access to confidential, proprietary or private information of various types, including student records, employee records, University business information, personally identifiable information, intellectual property and other information subject to contractual or legal obligations of confidentiality. All members of the University community must follow all applicable legal, contractual and policy restrictions on the use, disclosure and safeguarding of such information. Existing University policies, principles, and guidelines involving appropriate treatment of confidential information include without limitation:
Appropriate Use of University Resources and Accurate Financial Reporting. University resources are reserved for University business purposes. Therefore, all members of the University community are expected to ensure that University resources, such as funds and other property are used appropriately for the benefit of the University and in compliance with applicable laws and regulations and University policies, principles, procedures, and guidelines. When required by their job responsibilities, members of the University community must record, allocate, document and/or report revenue, expenditures, time, effort and other information in an accurate, complete and timely manner. All entries in University's books and records, including departmental accounts and individual expense reporting, must accurately reflect each transaction. Existing University policies, principles, procedures, and guidelines involving appropriate use of University resources and accurate financial reporting include without limitation:
Reporting Suspected Violations. Each member of the University community has the responsibility to ask questions, seek guidance and report suspected violations of this Code or any other applicable law or regulation, contractual or other obligation of the University or of University policy, principle, procedure, or guideline. Individuals are encouraged to report suspected violations through standard management channels, such as to their immediate supervisor or other appropriate University officials. However, an individual who for any reason feels uncomfortable reporting a suspected violation through established channels may file an anonymous report through the University's Ethics Reporting Hotline:

CARNEGIE MELLON UNIVERSITY ETHICS REPORTING HOTLINE
TOLL FREE: 844-587-0793
Via the Internet: cmu.ethicspoint.com
Reports of suspected violations may be made confidentially, and even anonymously, although the more information that is given, the easier it is to investigate the reports. A report of a suspected violation is a service to the University and will not in itself jeopardize employment with the University. That is, no person who makes a good faith report of a suspected violation will be reprimanded or retaliated against in any way.
Consequences of Violations. Violations of this Code or any other applicable law or regulation, contractual or other obligation of the University or University policy, principle, procedure, or guideline may carry disciplinary or other consequences, including dismissal.

Footnote:

^{[1] As required by agreement with the United States Department of Defense, the University's Software Engineering Institute (SEI) has a separate Code of Business Ethics and Compliance that contains additional requirement for SEI employees.}