Purpose

This Code of Ethics is meant to serve as a guide to assist the Board of Governors, administrators, faculty, and staff of City University of Seattle (hereinafter collectively referred to as "Members of the University Community" in making ethical decisions and engaging in appropriate, lawful conduct. It is the intent of the Board of Governors that compliance with this Code of Ethics will foster a work environment that stimulates and challenges the development of abilities and pursuit of personal and professional growth while maintaining the highest ethical standards and the goals of City University of Seattle. The Board of Governors of City University of Seattle encourages Members of the University Community to develop moral and ethical commitments to themselves, work, society, and the world.

Introduction

City University of Seattle is committed to the highest standards of educational quality, including the highest standards of legal and ethical conduct in its business practices. The continued success and strong public image of City University of Seattle is dependent upon the ethical conduct of its Board of Governors, administrators, faculty, and staff. This Code of Ethics contains principles articulating the policy of the University and standards, which are intended to provide additional guidance. All Members of the University Community are responsible to ensure that their behavior and activity is consistent with this Code of Ethics, as well as University policies and procedures, and applicable federal, state and local laws, and regulations.

Any questions regarding the City University of Seattle Code of Ethics, including questions concerning the interpretation or application of the Code, should be directed to the Office of the President. This Code of Ethics shall be distributed annually to all Members of the University Community.

City University of Seattle will strive to ensure that all activity by or on behalf of the University is in compliance with the Articles of Incorporation and the Bylaws of City University of Seattle, the standards of academic accreditation promulgated by the Northwest Commission on Colleges and Universities or other applicable accreditation authorities, and all applicable federal, state and local laws, and regulations, whether or not specifically addressed in this Code of Ethics.

Standard 1.1 Tax

As a nonprofit entity under Section 501(c)(3) of the Internal Revenue Code, the University has a legal and ethical obligation to act in compliance with applicable laws, to engage in activities in furtherance of its educational and charitable purpose, and to ensure that its resources are used in a manner that furthers the public good rather than the private or personal interests of any individual. Consequently, the University and Members of the University Community will avoid compensation arrangements in excess of fair market value, will accurately report payments to appropriate taxing authorities, and will file all tax and information returns in a manner consistent with applicable laws.

Standard 1.2 Equal Opportunity and Non-Discrimination

City University of Seattle is an equal opportunity employer and is committed to maintaining a professional working environment that is free from discrimination and unlawful harassment. The Board of Governors, officers, faculty, and staff of City University of Seattle shall:

• Respect others without regard to race, sex, religion, age, color, creed, national or ethnic origin, physical, mental or sensory disability, marital status, sexual orientation, or status as a Vietnam-era or disabled veteran.
• Not engage in or tolerate any conduct which constitutes unlawful harassment or discrimination.
• Work together to promote a productive, professional working and learning environment.

Any allegation of harassment or discrimination will be promptly investigated and addressed in accordance with applicable human resources policies.

Standard 1.3 Political Contributions and Civic Involvement

As a nonprofit entity under in section 501(c)(3) of the Internal Revenue Code, City University of Seattle is prohibited from making contributions to any candidate for political office and from intervening in any political campaign on behalf of or in opposition to any candidate for public office. City University of Seattle encourages individual participation and involvement in civic activities, including political activities, but individuals engaged in such activities may not act in any way that implies that personal involvement is endorsed by or conducted on behalf of City University of Seattle. Except as otherwise provided by law, the Members of the University Community shall:

• Refrain from using City University of Seattle's funds or other resources to endorse or oppose a candidate for public office or conduct other related political activities.
• Refrain from engaging in any political activities, including but not limited to solicitation of funds, lobbying or circulating political literature on City University of Seattle premises.
• Refrain from engaging in any political activities, including but not limited to making any political contributions to any candidate for public office in any jurisdiction, in a manner that may create the appearance that the activity is endorsed by or undertaken on behalf of City University of Seattle.

Where its experience may be helpful, the University may publicly offer recommendations concerning legislation or regulations being considered. In addition, it may analyze and take public positions on issues that have a relationship to the operations of the University when the University's experience contributes to the understanding of such issues.

The University has many contacts and dealings with governmental bodies and officials. All such contacts and transactions shall be conducted in an honest and ethical manner. Any attempt to influence the decision-making process of governmental bodies or officials by an offer of any benefit is prohibited.

Standard 1.4 Financial Aid Programs

It is the policy of the University to comply with all laws, regulations, and standards relating to the University's participation in federal or state financial aid programs for students.

Standard 1.5 Environmental

It is the policy of the University to manage and operate its business in the manner that respects our environment and conserves natural resources. Members of the University Community will strive to utilize resources appropriately and efficiently, to recycle where possible, and otherwise handle all hazardous materials and dispose of all waste in accordance with applicable laws and regulations, and to work cooperatively with the appropriate authorities to remedy any environment contamination for which the University may be responsible.

In furtherance of the University's commitment to the highest standards of business ethics and integrity, Members of the University Community will accurately and honestly represent the University and will not engage in any activity or scheme intended to defraud anyone of money, property, or honest services. Our reputation and integrity are central to City University's ability to operate worldwide. The standards set forth below are designed to provide guidance to ensure that the University's business activities reflect the highest standards of business ethics and integrity.

Standard 2.1 Professional Excellence and Personal Integrity

City University of Seattle promotes professional excellence in all employment categories. City University of Seattle's administrators, faculty, and staff are comprised of distinguished practitioners in the fields of business, education, government, human services, civic and research organizations, and the legal community. Faculty members combine strong academic preparation and active professional careers in the fields that they teach. This combination of academic strength and practical experience is the most salient characteristic of City University of Seattle and assures the relevance, currency and credibility of the institution.

The Members of the University Community shall:

• Pursue the highest possible standards of performance, quality, service, and achievement while working to fulfill the mission, goals, and objectives of City University of Seattle.
• Observe the highest standards of professionalism at all times.
• Exhibit a high degree of personal integrity at all times.
• Strive to develop educational programs that are current, relevant, and non-repetitious.
• Pursue creation of an environment that encourages experimentation and innovation by students, faculty, staff, and the institution as a whole.
• Refuse to engage in or tolerate any fraud, misuse, abuse or waste of City University of Seattle's resources.
• Honor the privacy of students, colleagues, and others.
• Show respect for students and colleagues and treat them fairly.
• Approach all issues with an open mind.
• Solicit the opinions of others and encourage different viewpoints.
• Make every effort to resolve dissent and discord, and if it cannot be resolved, keep it in perspective and respect and support the decision and the decision-maker(s).
• Encourage the reporting of violations of this Code of Ethics and protect those who do report.

Standard 2.2 Honest Communication

The University requires candor, honesty, and cooperation from individuals in the performance of their responsibilities and in communication with our attorneys and auditors. No Member of the University Community shall make false or misleading statements to any student, person, or entity doing business with the University about other students, persons, or entities doing business or competing with the University, or about the services or programs of the University of its competitors.

Standard 2.3 Accountability

City University of Seattle owes responsibilities to its stakeholders, who include students, donors, funders, and others. These stakeholders have placed their faith and trust in this institution.

The Members of the University Community shall:

• Strive to protect City University of Seattle's positive public image and credibility.
• Operate in a manner that ensures cost-effective use of available resources and maintains sound business practices.
• Develop and utilize administrative and educational systems that are efficient and effective.
• Make full and fair disclosure of all relevant financial and other information to stakeholders who have a right to know how their money is being spent.
• Strive to protect City University of Seattle's resources from unauthorized use, abuse, waste, loss or significant damage.
• Comply with all laws and regulations applicable to City University of Seattle.

Standard 2.4 Misappropriation of Proprietary Information

Members of the University Community shall not misappropriate confidential or proprietary information belonging to another person or entity nor utilize any publication, document, computer program, information, or product in violation of a third party's interest in such product. All Members of the University Community are responsible to ensure that they do not improperly copy for their own use documents or computer programs in violation of applicable copyright laws or licensing agreements.

All Members of the University Community shall strive to maintain the confidentiality of confidential information in accordance with legal and ethical standards. Members of the University Community are in possession of and have access to a broad variety of confidential, sensitive, and proprietary information, the inappropriate release of which could be injurious to individuals, affiliated institutions and parties with which the University does business, and the University itself. Each Member of the University Community has an obligation to actively protect and safeguard confidential, sensitive, and proprietary information in a manner designed to prevent the unauthorized disclosure of such information.

Standard 3.1 Proprietary Information

Information, ideas and intellectual property assets of the University are important to organizational success. Information pertaining to the University's competitive position or business strategies and information relating to negotiations with Members of the University Community or third parties should be protected and shared only with Members of the University Community having a need to know such information in order to perform their job responsibilities. Members of the University Community should exercise care to ensure that intellectual property rights, including patents, trademarks, copyrights, and software, is carefully maintained and managed to preserve and protect its value.

Standard 3.2 Personnel Actions/Decisions

Salary, benefit, and other personal information relating to Members of the University Community shall be treated as confidential. Personnel files, payroll information, disciplinary matters, and similar information shall be maintained in a manner designed to ensure confidentiality in accordance with applicable laws. Members of the University Community will exercise due care to prevent the release or sharing of information beyond those persons who may need such information to fulfill their job function.

Standard 3.3 Student Educational Records

Student educational records will be maintained in accordance with applicable laws and regulations. Members of the University Community will exercise due care to prevent the release or disclosure of information beyond these persons who are authorized by applicable law to access such information.

All Members of the University Community owe a duty of undivided and unqualified loyalty to the organization and may not use their positions to profit personally or to assist others in profiting in any way at the expense of the organization. All Members of the University Community are expected to regulate their activities so as to avoid actual impropriety and or the appearance of impropriety which might arise from the influence of those activities on business decisions of the University, or from disclosure or private use of business affairs or plans of the University.

Standard 4.1 Outside Financial Interests

While not all inclusive, the following will serve as a guide to the types of activities by a Member of the University Community, or immediate family member (spouse, parents, children, siblings) of such person, which might cause conflicts of interest:

1. Financial and ownership interests in or employment by any outside concern which does business with the University. "Ownership interests" include interests in a partnership in which the member has more than a 5% ownership interest (including spouse and children) in a partnership. For purposes of this policy, a member is not deemed to hold any ownership interest in a publicly-held corporation if his/her only interest in that corporation is an equity (stock) ownership of 5% or less (including spouse and children) of any class of that corporation's securities. The University may, following a review of the relevant facts, permit ownership interests which exceed these amounts if management concludes such ownership interests will not adversely impact the University's business interest or the judgment of the member.
2. The University considers a significant financial interest to be anything of monetary value including equity interest. An equity interest when aggregated for the member and the member's spouse and dependent children must not exceed $10,000 in value and must not represent more than a 5% ownership interest in a single entity. Salary, royalties, or other payments when aggregated for the member and the member's spouse and dependent children are not to exceed $10,000 in a twelve-month period.
3. Conduct of any business not on behalf of the University, with any vendor, supplier, contractor, or agency, or any of their officers or agents.
4. Representation of the University by a member in any transaction in which (s)he or an immediate family member has a substantial personal interest.
5. Disclosure or use of confidential, special or inside information of or about the University, particularly for the personal profit or advantage of the member or an immediate family member.
6. Competition with the University by a member, directly or indirectly, in the purchase, sale or ownership of property or property rights or interests, or business investment opportunities.
7. Disclosure of any personal activity or business opportunity which is within the scope of the activities of the University and exploitation of such opportunity, except upon written approval of the President.
8. Participation in a transaction with the University for personal profit except upon the written approval of the President, which approval should be disclosed in a Conflict of Interest Statement.

Standard 4.2 Services for Competitors/Vendors

No Member of the University Community shall perform work or render services for any competitor of the University or for any organization with which the University does business or which seeks to do business with the University outside of the normal course of his/her employment with the University without the approval of the President or the member's supervisor. Nor shall any such member be a trustee, officer, or consultant of such an organization, nor permit his/her name to be used in any fashion that would tend to indicate a business connection with such organization.

Standard 4.3 Participation on Boards of Directors or Trustees

1. A Member of the University Community must obtain approval from his/her supervisor prior to serving as a member of the Board of Directors or Trustees of any organization whose interests may conflict with those of the University.
2. A Member of the University Community who is asked, or who seeks to serve on the Board of Directors or Trustees of any organization whose interest would not impact the University (for example, civic, charitable, fraternal and so forth) will not be required to obtain such approval.
3. All fees/compensation (other than reimbursement for expenses arising from Board participation) that are received for Board services provided during normal work time shall be paid directly to the University.
4. The University retains the right to prohibit membership on any Board of Directors or Trustees where such membership might conflict with the best interest of the University.

Standard 4.4 Honoraria

Members of the University Community, with the permission of their supervisor, are encouraged to participate as faculty and speakers at educational programs and functions. However, any honoraria in excess of One Thousand Dollars ($1,000.00) shall be turned over to the University unless approved in advance by the University President.

To the extent that there is a conflict between the provisions of this Principal 4 and any other policy or procedure governing the members of the Board of Governors and/or the officers of the University, including those set forth in the Board of Governors Policy Handbook, the provisions of the Board of Governors Policy Handbook, or other Board policy or procedure shall govern.

Business transactions with vendors, contractors and other third parties shall be transacted free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction.

The standards set forth below are intended to guide Members of the University Community in determining the appropriateness of the listed activities or behaviors within the context of the University's business relationships, including relationships with vendors, providers, contractors, third party payors, and government entities. It is the intent of the University that this policy be construed broadly to avoid even the appearance of improper activity. If there is any doubt or concern about whether specific conduct or activities are ethical or otherwise appropriate, you should contact the University President.

Standard 5.1 Gifts and Gratuities

It is the University's desire to at all times preserve and protect its reputation and to avoid the appearance of impropriety through implementation of the following Standards:

1. Gifts Influencing Decision-making. Members of the University Community shall not accept gifts, favors, services, entertainment, or other things of value to the extent that decision-making or actions affecting the University might be influenced. Similarly, the offer or giving of money, services or other things of value with the expectation of influencing the judgment or decision-making process of any purchaser, supplier, customer, government official or other person by the University is prohibited. Any such conduct must be reported immediately either to the University President or to the Chief Financial Officer.
2. Gifts From Existing Vendors. Members of the University Community may retain gifts from vendors which have a nominal value. The University expects Members of the University Community to exercise good judgment and discretion in accepting gifts). If a Member of the University Community has any concern as to whether a gift should be accepted, that person should consult with his/her supervisor. To the extent possible, these gifts should be shared with the employee's co-workers. Members of the University Community shall not accept excessive gifts, meals, expensive entertainment, or other offers of goods or services which have more than a nominal value nor may they solicit gifts from vendors, suppliers, contractors, or other persons.
3. Vendor Sponsored Entertainment. At a vendor's invitation, an individual may accept meals or refreshments at the vendor's expense. Occasional attendance at a local theater or sporting event, or similar entertainment at vendor expense may also be accepted. In most circumstances, a regular business representative of the vendor should be in attendance with the Member of the University Community.
4. While City University of Seattle encourages and willingly accepts grants and donations to the University, Members of the University Community may not accept gifts and/or gratuities from City University of Seattle students other than those of nominal value.

Standard 5.2 Workshops, Seminars and Training Sessions

Attendance at local, vendor-sponsored workshops, seminars, and training sessions is permitted. Attendance, at vendor expense, at out-of-town seminars, workshops, and training sessions is permitted only with the approval of an employee's supervisor.

Standard 5.3 Contracting

Members of the University Community may not utilize "insider" information for any business activity conducted by or on behalf of the University. All business relations with contractors must be conducted at arm's length both in fact and in appearance and in compliance with University policies and procedures. Members of the University Community must disclose personal relationships and business activities with contractor personnel which may be construed by an impartial observer as influencing the Member's performance or duties. Members of the University Community have a responsibility to obtain clarification from management employees on questionable issues which may arise and to comply, where applicable, with the University's conflict of interest policy.

Standard 5.4 Business Inducements

Members of the University Community shall not seek to gain any advantage through the improper use of payments, business courtesies, or other inducements. Offering, giving, soliciting, or receiving any form of bribe or other improper payment is prohibited.

Appropriate commissions, rebates, discounts, and allowances are customary and acceptable business inducements provided that they are approved by the University management and that they do not constitute illegal or unethical payments. Any such payments must be reasonable in value, competitively justified, properly documented, and made to the business entity to which the original agreement or invoice was made or issued. Such payments should not be made to individual Members of the University Community or agents of business entities.

In addition, Members of the University Community may provide gifts, entertainment, and meals of nominal value to University customers, current and prospective business partners, and other persons when such activities have a legitimate business purpose, and are reasonable and consistent with all applicable laws.

All Members of the University Community will strive to preserve and protect the University's assets by making prudent and effective use of University resources and properly and accurately reporting its financial condition.

The standards set forth below are intended to guide Members of the University Community by articulating the University's expectations as they relate to activities or behaviors which may impact the University's financial health or which reflect a reasonable and appropriate use of the assets of a nonprofit entity.

Standard 6.1 Internal Control

The University has established control standards and procedures to ensure that assets are protected and properly used and that financial records and reports are accurate and reliable. All Members of the University Community share the responsibility for maintaining and complying with required internal controls.

Standard 6.2 Financial Reporting

All financial reports, accounting records, research reports, expense accounts, time sheets, and other documents must accurately and clearly represent the relevant facts or the true nature of a transaction. Improper or fraudulent accounting, documentation, or financial reporting is contrary to the policy of the University and may be in violation of applicable laws.

Standard 6.3 Travel and Entertainment

Travel and entertainment expenses should be consistent with each Member of the University Community's job responsibility and the University's needs and resources. It is the University's policy that a Member of the University Community should not suffer a financial loss or a financial gain as a result of business travel and entertainment. Members of the University Community are expected to exercise reasonable judgement in the use of the University's assets and to spend the University's assets as carefully as they would spend their own. Members of the University Community must also comply with University policies relating to travel and entertainment expenses.

Standard 6.4 Personal Use of University Assets

No Member of the University Community shall convert assets of the University to personal use. All University property shall be used and business shall be conducted in a manner designed to further the University's interest rather than the personal interest of individual Members of the University Community. Members of the University Community are prohibited from the unauthorized use or taking of the University's equipment, supplies, materials, or services. Prior to engaging in any activity during working hours which will result in remuneration to Members of the University Community or the use of the University's equipment, supplies, materials, or services for personal or non-work related purposes, Members of the University Community shall obtain the approval of the appropriate business unit or other management of the University.

The University expects each person to whom this Code of Ethics applies to abide by the Principles and Standards set forth herein and to conduct the business and affairs of the University in a manner consistent with the general statement of principles set forth herein. As part of this responsibility, all Members of the University Community are expected to report any activity or practice that may violate this Code of Ethics to their supervisor, the University President, or the Confidential Hotline. Failure to abide by this Code of Ethics or the guidelines for behavior which the Code of Ethics represents may lead to disciplinary action. For alleged violations of the Code of Ethics, the University will weigh relevant facts and circumstances, including, but not limited to, the extent to which the behavior was contrary to the express language or general intent of the Code of Ethics, the egregiousness of the behavior, the employee's history with the University, and other factors which the University deems relevant. Discipline for failure to abide by the Code of Ethics may, in the University's discretion, range from oral correction to termination.

Nothing in this Code of Ethics is intended to or shall be construed as providing any additional employment or contract rights to any Member of the University Community.

While the University will generally attempt to communicate changes concurrent with or prior to the implementation of such changes, the University reserves the right to modify, amend or alter the Code of Ethics without notice to any Member of the University Community.