Code of Conduct Policy

Responsible Unit: CEIS | Executive lead: President
Created: 9/2021 | Reviewed/Revised: 4/22/2023 | Effective: 4/22/2023
Compliance: NWCCU 2.C.2, 2.F.1
Approving Body: BOT | Classification: Institution-wide

Policy:
Pacific Northwest University of Health Sciences Code of Conduct
In furtherance of promoting and maintaining integrity at Pacific Northwest University of Health Sciences (PNWU), the Board of Trustees has promulgated this Code of Conduct, which sets forth the general principles to which we subscribe and to which we expect every University staff member, faculty member, officer, trustee, and board member; and every contractor, agent, or other acting on behalf of the University, to adhere. These principles have been derived from federal, state, and local laws and regulations, University policies and procedures, contractual and grant obligations, and generally accepted principles of ethical conduct.

Adherence to the Highest Ethical Standards
Every member of the University shall, at all times, conduct their activities in accordance with the highest professional and community ethical standards.

Respect for and Compliance with the Law
Every member of the University is expected to become familiar with those laws, regulations, and University policies and procedures which are applicable to their position and duties, and to comply in both letter and spirit. The University will implement programs to further members’ awareness and to monitor and promote compliance. All questions and concerns about the legality or propriety of any action or failure to take action by or on behalf of the University should be referred to either the member’s supervisor or to the Office of Compliance, Ethics, and Integrity Services.

Compliance with All Contractual and Grant Terms and Conditions
Every member of the University is expected to maintain access to and to comply strictly with the terms and conditions of each University grant and contract on which they work. All questions or concerns about whether a particular term or condition violates the law or whether any party to the contract has breached its obligations should be referred promptly to the Office of Compliance, Ethics, and Integrity Services.

Support the University’s Goals and Avoidance of Conflict of Interest
PNWU is a nonprofit institution which is dedicated to teaching and research. Every member of the University is expected to faithfully carry out their professional duties in furtherance of the University’s mission. Every member has a duty to avoid conflicts between their personal interests and official responsibilities and to comply with University policies and procedures for reporting and reviewing actual and potential conflicts of interest and conflicts of commitment. Additionally, a member may not utilize their position with the University for personal benefit. Members are also expected to consider and avoid, not only an actual conflict but also, the appearance of a conflict of interest.

Maintenance of the Highest Standards of Academic Integrity
Every member of the University involved in teaching and research activities is expected to conform to the highest standards of honesty and integrity. Activities such as plagiarism, misrepresentation, and falsification of data are expressly prohibited. All research at the University must be conducted in strict conformity with the applicable University policies, procedures, and approvals and the requirements of all governmental and private research sponsors.

Respect for the Rights and Dignity of Others
PNWU is committed to equal treatment, opportunity, and respect in its relations with its faculty, administrators, staff, students, and others who come into contact with the University. Every member of the University is prohibited from discriminating on the basis of race, color, religion, sexual orientation, gender and/or gender identity or expression, marital or parental status, national origin, citizenship status, veteran or military status, age, disability, and any other legally protected status; physically assaulting, emotionally abusing, or harassing anyone; and depriving anyone of rights in their physical or intellectual property, under University policy, or under federal, state, and local laws.

Conducting Business Practices with Honesty and Integrity
Every member of the University is expected to conduct all business with payors, vendors, competitors, and the academic community with honesty and integrity. This duty includes but is not limited to: adherence to federal and state anti-fraud and referral prohibitions in dealing with vendors and referral sources; adherence to all antitrust laws (such as those governing prices and other sales terms and conditions, and improper sharing of competitive information); and protecting and preserving University property and assets—including proprietary intellectual property, buildings, equipment, books, supplies, and funds.

Proper Accounting for University Resources
The University is committed to creating and maintaining financial books and business records that fairly, accurately, and completely report all funds, assets, liabilities, revenues, expenses, and financial statements and represent the true financial condition of PNWU. Books and records must be maintained in accordance with generally accepted accounting principles and all applicable laws and regulations.

Fiscal responsibility is not limited to accounting and auditing personnel. All members, including those who negotiate or authorize sales and purchase contracts, submit expense reports, or prepare or pay invoices should protect and preserve the University’s resources by keeping accurate records.

University members are prohibited from taking any action to fraudulently influence, coerce, manipulate, or mislead any independent public or certified accountant performing an audit of the University’s financial statements for the purpose of rendering such financial statements materially misleading.

Maintaining University Records
Records kept in the course of our work at PNWU are important University resources. Prompt, accurate and secure record keeping is essential. Every University member is responsible for creating, using, storing, preserving and, as appropriate, disposing of records according to PNWU policies and procedures, as well as all federal, state, and local laws and regulations.

Concern for Health and Safety; Respecting the Environment
Every member of the University is expected, in the performance of their duties, to comply with all laws and regulations which govern occupational safety and to make every reasonable effort to ensure that students, faculty, patients, employees, and visitors are protected from undue health risks and unsafe conditions.

Every member of the University is expected, in the course of their activities, to comply with all applicable environmental laws and regulations; to ensure that the University has obtained all necessary licenses, permits, and approvals; and to employ the proper procedures and controls in the storage and handling of toxic materials and in the handling and disposition of hazardous and biohazardous wastes.

Respecting Intellectual Property Rights
In addition to creating original scholarship, the University community also extensively uses copyrighted works for academic endeavors and other University affairs. Where a member uses copyrighted materials, the University expects all community members to adhere to copyright laws and the University’s Copyright Policy, and to obtain the copyright holder’s permission whenever appropriate.

Safeguarding University Information Technology Resources
As members of the University community, we must protect PNWU information technology and communication systems from misuse, inappropriate or unauthorized access, damage, or destruction. Incidents or security breaches involving

PNWU’s information technology and communications systems could lead to the loss, misuse, or theft of information pertaining to employees, students, or the University and could expose the community to substantial risks and damage the reputation of the University. Any such incidents should be reported immediately to Technology Services or the Office of CEIS.

Assuring Data Privacy and Protection
PNWU collects, processes, and stores a substantial amount of academic, research, personal, administrative, and clinical information and records. We are all responsible for maintaining the privacy, security and confidentiality of University records and for following the policies and procedures promulgated by the University for their maintenance and protection. University members who have access to personally identifiable information of students, employees, and others should familiarize themselves with University policies that explain relevant laws and regulations, such as Family Educational Rights and Privacy Act (FERPA), which protects information about students; and the Health Insurance Portability and Accountability Act (HIPAA), which protects patient information.

Failure to protect sensitive data from loss, release, or improper disclosure can disrupt business operations, impede research, result in legal penalties, and damage the University’s reputation.

Reporting Suspected Violations of the Code; Enforcement of the Code
This Code of Conduct has been created and exists for the benefit of the entire University and all of its members. It exists in addition to and is not intended to limit the specific policies and procedures enacted by the University and each of its Schools.

Each member of the University is expected to uphold the standards of PNWU and to report suspected violations of the Code or any other apparent irregularity to either their supervisor, Human Resources, the Title IX officer, the applicable office or department, or the Office of Compliance, Ethics, Integrity Services.

The University will, if requested, make every reasonable effort to keep confidential the identity of anyone reporting a suspected violation, to the extent permitted or required by law, and except if doing so would effectively prevent the University from conducting a full and fair inquiry of the allegations.

This Code of Conduct will be enforced. Reports of suspected violations will be examined by authorized University personnel. Officers, managers, and supervisors have a special duty to adhere to the principles of the Code, to encourage their subordinates to do so, and to recognize and report suspected violations. Each member of the University is expected to cooperate fully with any inquiry undertaken. If it is determined that a violation has occurred, the University reserves the right to take corrective and disciplinary action against any person who was involved in the violation or who allowed it to occur or persist due to a failure to exercise reasonable diligence. Additionally, the University may make an appropriate disclosure to governmental agencies (including law enforcement authorities). Disciplinary actions will be determined on a case-by-case basis and in accordance with the applicable disciplinary codes.

Promise of No Retaliation
The University promises that there will be no adverse action, retribution, or other reprisal for the good faith reporting of a suspected violation of this Code, even if the allegations ultimately prove to be without merit. The University will, however, pursue disciplinary action against any member who is shown to have knowingly filed a false report with the intention to injure another.

The University reserves the right, at any time, and without notice, to amend this Code of Conduct in its sole, good faith, discretion. This Code does not form a contract.

Adapted with permission from New York University (NYU) Code of Conduct, September 2021.

Definitions:
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Procedure:
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