Fiscal Code of Ethics

The University has a fiduciaryFiduciaryThe obligation arising from a position of authority to act on behalf of another (as in managing the University's operations) where one assumes a duty to act in good faith and with care, candor, and loyalty. responsibility to fulfill its overall mission in compliance with applicable policies, laws, regulations and rules, and contracts, grants and donor restrictions. Under Regent Policy, all employeesEmployeesAn individual who currently holds a University employment appointment, whether full-time, part-time, temporary, seasonal or hourly. are entrusted with the responsibility of preserving university resourcesUniversity resourcesOfficial resources of the institution, including but not limited to: university funds, facilities, personnel/labor, equipment (e.g., telephones, photocopy machines, computers – including email), work products, results, materials, records, or other information developed or produced with university goods or services. and using those resources in a prudent manner for their designated purposes, as prescribed by policies, laws, regulations, and rules, and contracts, grants and donor restrictions [Regent Policy 13-R.III].

This policy statement sets forth the university's Fiscal Code of Ethics. This policy applies to all employees. In addition, if an affiliate'sAffiliateAn organization that has a contractual or other legal relationship with the University that closely aligns them operationally with the University to more effectively further both the University and the organization's missions. Affiliates are identified at https://www.cusys.edu/controller/policies/supporting%20listing.doc. Affiliates include Blended Organizations and Supporting Organizations. employee agrees to conduct fiscal transactionsFiscal transactionsFinancial transactions occur within numerous University functions including Accounting, Human Resources, Payroll and Benefits, Procurement and Student Services. EXAMPLES OF FISCAL TRANSACTIONS Function/Transaction • Accounting o Asset Transfers/Disposition o Cash Transfer o Journal Entry (JE) o Interdepartmental Invoice/Order • Human Resources, Payroll and Benefits o Create or Modify Position (Employment Management) o One Time Payment (Payroll) o Payroll Expense Transfer (PET) o Payroll Funding Distribution o Time Collection Entry • Procurement (Purchasing, Payables or Travel) o Cash Advance o Departmental Purchase Order o International Travel Meal Diary Form o Official Function Form o Petty Cash o Procurement Card Allocation o Procurement Card Purchase o Payment (Expense) Voucher o Purchase Requisition o Standing Purchase Order Renewal/Requisition o Travel Authorization/Advance o Travel Voucher o Unavailable Documentation • Student Services / Bursar o Cash Receipt o Financial Aid Award o Tuition and Fee Charge o Tuition Waiver on behalf of the University as a resulting condition of her or his duties, this policy applies to all affiliate fiscal staffAffiliate fiscal staffEmployee(s) of an Affiliate(s) that accepts a role as Fiscal Staff for the University through a written agreement. in conducting the university's fiscal transactions. Furthermore:

• As public employees, employees are obligated to comply with the code of ethics established in state law [C.R.S. 24-18-101 through 24-18-105, and 24-18-108 through 24-18-110].
• State criminal statutes provide criminal sanctions for employees who fail to disclose a conflict of interestConflict of interestSituations defined in the Administrative Policy Statement Conflict of Interest Policy in which financial or other personal considerations may compromise, or have the appearance of compromising, an employee's professional judgment in administration, management, instruction, research and other professional activities. This includes situations in which an employee might derive private gain due to her/his association with the University. [C.R.S. 18-8-308]; misuse official information [C.R.S. 18-8-402]; engage in official misconduct [C.R.S. Section 18-8-404 and 405]; or embezzle public property [C.R.S. Section 18-8-407].
• If the fiscal transaction involves university fundsUniversity fundsAll funds appropriated, generated, awarded, donated or otherwise received by the University regardless of their source. With the exception of University Physicians Incorporated (UPI) funds, the term University Funds does not include Agency Funds (Fund 80) that the University maintains for legally separate External Student Organizations or other entities. that were received from a federal sponsor, employees and affiliate fiscal staff must comply with applicable federal regulations and may be subject to sanctions detailed therein.

1. Officers - as set forth in the Administrative Policy Statement (APS) Fiscal Roles and Responsibilities - are entrusted with fiscal responsibility for their functional area of responsibilityFunctional area of responsibilityA group of related business objectives, processes and entities for which an Officer has oversight by virtue of her/his position that have the following characteristics: organizational permanency and programmatic autonomy. and are responsible for setting a tone within their functional area of responsibility (and the University as a whole) for ethical conduct and integrity.
2. Officers are required to adhere to the Officer's Fiscal Code of Ethics.
3. EmployeesEmployeesAn individual who currently holds a University employment appointment, whether full-time, part-time, temporary, seasonal or hourly. are required to adhere to the Employee's Fiscal Code of Ethics.
4. Officers, Finance System usersFinance system usersEmployees or affiliate fiscal staff who have access to the university's Finance System., HRMS usersHRMS usersEmployees or affiliate fiscal staff who have access to the university's HRM., and Procurement Card usersProcurement card usersEmployees or affiliate fiscal staff who are assigned a role as Cardholder, Approving Official, or Reallocator associated with a university Procurement Card. - whether employees or affiliate fiscal staffAffiliate fiscal staffEmployee(s) of an Affiliate(s) that accepts a role as Fiscal Staff for the University through a written agreement. - are required to demonstrate their awareness of and compliance with the appropriate Fiscal Code of Ethics through the process described in the Finance Procedural Statement (FPS) Fiscal Code of Ethics Acknowledgement.
5. Officers must ensure that all employees working on a federal contract valued at or above $5 million demonstrate their awareness of and compliance with the appropriate Fiscal Code of Ethics through the process described in the Finance Procedural Statement (FPS) Fiscal Code of Ethics Acknowledgement.
6. Each officer may require other employees to demonstrate their awareness of and compliance with the Employee's Fiscal Code of Ethics through the process described in the FPS.

A. Attachments

• Employee's Fiscal Code of Ethics
• Officer's Fiscal Code of Ethics

B. Procedures

• Finance Procedural Statement (FPS) Fiscal Code of Ethics

C. Related Administrative Policy Statements

The Accountability Suite of Fiscal Policies sets forth a number of requirements whose ultimate aim is to assure ethical conduct in processing university fiscal transactionsFiscal transactionsFinancial transactions occur within numerous University functions including Accounting, Human Resources, Payroll and Benefits, Procurement and Student Services. EXAMPLES OF FISCAL TRANSACTIONS Function/Transaction • Accounting o Asset Transfers/Disposition o Cash Transfer o Journal Entry (JE) o Interdepartmental Invoice/Order • Human Resources, Payroll and Benefits o Create or Modify Position (Employment Management) o One Time Payment (Payroll) o Payroll Expense Transfer (PET) o Payroll Funding Distribution o Time Collection Entry • Procurement (Purchasing, Payables or Travel) o Cash Advance o Departmental Purchase Order o International Travel Meal Diary Form o Official Function Form o Petty Cash o Procurement Card Allocation o Procurement Card Purchase o Payment (Expense) Voucher o Purchase Requisition o Standing Purchase Order Renewal/Requisition o Travel Authorization/Advance o Travel Voucher o Unavailable Documentation • Student Services / Bursar o Cash Receipt o Financial Aid Award o Tuition and Fee Charge o Tuition Waiver and in the conduct of official university businessOfficial university businessAny activity that carries out the university's mission of instruction, research and service or that provides support to the university's instruction, research, and service activities.. The policies within this suite include this policy and the following:

• Controller Function Decentralization
• Fiscal Certification
• Fiscal Misconduct Reporting
• Fiscal Roles and Responsibilities
• Officer Disclosure of Interests

In addition, this policy is interrelated with the following Administrative Policy Statements:

• Conflicts of Interest and Commitment
• Misconduct in Research and Authorship

D. Related Policies

• University of Colorado Denver Health Care Professional Conflict of Interest Policy

E. Educational Resources

Educational resources including guides, training announcements, and newsletters are announced and available on the Office of University Controller and related websites.

• Fiscal Code of Ethics Skillsoft Course
• Sponsored Project Office Guidelines and Information

Italicized terms used in this Administrative Policy Statement are defined in the Administrative Policy Statement Glossary.

• Revised - November 1, 2008
• Initial Policy - June 30, 2005