Policies & Contracts

104 - Business Conduct

Subject: Business Conduct

Section: U104

Date: August, 2020


The purpose of this policy is to promote the University’s commitment to maintaining the highest ethical standards in its internal and external business dealings.

Who is governed by this policy:

This policy applies to all staff employees.

Policy statement:

University staff employees must conduct themselves with honesty and integrity and exercise sound judgment when engaging in activities and performing responsibilities on behalf of the University. In addition to these principles, all University staff employees must comply with University and department policies, professional standards, safety guidelines, and the letter and spirit of applicable laws and regulations.

  1. Working at The University: The University values diversity and champions the fundamental principle of treating others with respect. The University also is committed to providing a safe work environment in which discrimination, harassment, and acts or threats of violence are not tolerated. The University expects its staff employees to treat each other and those with whom they have business dealings on behalf of the University with respect, honesty, integrity, and civility. All University staff employees must comply with University and department policies, professional standard, health and safety guidelines (including those related to COVID-19), and the letter and spirit of applicable laws and regulations. (See Policies U201 Equal Opportunity Employment, U609 Harassment, Discrimination and Sexual Misconduct, and U208 Termination of Employment.)
  2. Conflicts Of Interest: The University understands that its staff employees may have or be involved in outside financial, business, professional, academic, public service, or other activities. However, outside activities or commitments, familial or other relationships, private financial or other interests, and benefits or gifts received from third parties may create an actual or perceived conflict of interest between the staff employee and the University. A conflict of interest is a situation, arrangement, or circumstance where the staff employee’s outside or private interests or relationships interfere or appear to interfere with those of the University or cast doubt on the fairness or integrity of the University’s business dealings. Every staff employee is responsible for disclosing to his or her supervisor, Human Resources, or the Office of Legal Counsel any financial or personal interests, activities, or personal or familial relationships that create an actual or perceived conflict of interest. See Policies U600 Conflict of Interest and U206 Nepotism.)
  3. Confidentiality and Privacy: The University entrusts its staff employees with the confidential information of the University and, at times, others. Each University staff employee is responsible for protecting this information and preventing misuse or unauthorized disclosure. Confidential Information must only be accessed, disclosed, transmitted, used, stored, or disposed of with care and for appropriate University purposes. (See Policy U601 Treatment of Confidential Information.)
  4. University Records: All University accounting, financial records, expense reimbursements, time and attendance records, and submissions to governmental agencies must be truthful, timely, complete, and accurate. Specific guidance regarding University financial transactions and records is available on the Finance and Administration website and in the Policy U502 Attendance.
  5. Use of University Resources: All University staff employees are responsible for protecting and preventing the misuse of University resources, property, and other assets, including but not limited to, funds, information, intellectual property, facilities, office supplies, equipment, computers, networks, software, telephone and internet services, voice mail, and e-mail. University resources are reserved for University business and may only be used for lawful and authorized purposes. University systems such as computers and e-mail may be used for reasonable and incidental personal use. (See the Financial Policies, Information Technology Policies, and Property Management Manual.)
  6. Purchasing and Vendor Practices: All University staff employees must act in a fair and professional manner when engaging in commercial activities on behalf of the University, e.g., purchasing goods and services. Commercial transactions must take place in a competitive environment free from conflicts of interest. The University’s goal is to have a diverse pool of vendors and suppliers and to obtain the best possible value based on quality, price, service, reliability, and delivery terms. Goods and services may only be purchased by authorized individuals consistent with the Procurement Policies in the Financial Policies. Purchasing and Payment Services can provide guidance concerning the full spectrum of University commercial activities involving the purchase of goods and services.
  7. Unauthorized Recordings: No employee may record the conversation of another employee without the full knowledge and consent of all parties to a conversation.
    • Consent to record may be implied, such as when a participant at a meeting or conference speaks directly into or at a recording device (such as a microphone or video camera) or a recording light is activated. In those instances, the person making the recording should inform others of the fact of the recording. 
    • Express consent is required in situations when it may not be obvious or apparent to participants that the meeting is being recorded (such as, no recording light exists or participation by telephone). Any individual wishing to record the conversation shall notify all participants and obtain their consent in writing prior to initiating their recording device.  
    • Failure to obtain consent may result in civil and criminal liability to the person doing the recording, in addition to adverse action under this policy.
  8. Reporting Responsibilities & Procedures: All University staff employees should promptly notify the University of inappropriate conduct so that it can be properly addressed. University staff employees who are aware of or suspect fraud, misappropriation of funds, theft, other misuse of University resources or assets, accounting irregularities, violation of health and safety guidelines (including those related to COVID-19), or other violation of these principles or University policy, should report their concerns immediately to their supervisor, the Office of Risk Management, Human Resources (staff employee related), the Office of the Provost (faculty or other academic appointee related), or the Office of Campus and Student Life (student related), or the University of Chicago Accident and Incident Reporting (UCAIR) system (for matters related to health and safety guidelines). Alternatively, concerns may be reported to the University’s Whistleblower hotline at 800.971.4317. (See Policy U103 Whistleblower.)
  9. Retaliation: The University prohibits retaliation against any person for making a report in good faith or cooperating in an investigation. Individuals who take retaliatory action will be subject to corrective action up to and including termination of employment.
  10. Violations: Every staff employee is responsible for complying with these principles and for taking action or reporting violations. Employees who fail to comply with the principles, including not reporting known unethical conduct, or who fail to cooperate in an investigation will be subject to corrective action up to and including termination of employment. 
Governed Party Roles and Responsibilities
Employee The Employee is responsible for conducting themselves in accordance with the policy.  

Related Information:

Policy U103 Whistleblower Policy

Policy U201 Equal Employment Opportunity

Policy U206 Nepotism

Policy U208 Termination of Employment

Policy U502 Attendance Policy

Policy U600 Conflict of Interest

Policy U601 Treatment of Confidential Information Policy

Policy U609 Harassment, Discrimination and Sexual Misconduct

Policy U703 Progressive Corrective Action

Finance and Administration Website

Financial Policies

Information Technology Policies

Property Management Manual

Key Contacts:

Name Email Extension
Center of Expertise - Employee & Labor Relations elrelations@uchicago.edu 4-7345