Code of Conduct Policy
Royal Roads University Policy
Purpose: Code of Conduct
The purpose of this Code of Conduct Policy is to establish a set of standards of conduct for all employees of the university and for members of the Royal Roads University Board of Governors.
As a publically funded institution is it imperative that all university employees and Board of Governors members conduct themselves in an ethical manner, upholding high standards of conduct and care in all aspects of their employment or Board capacity with Royal Roads University (RRU).
Every employee of RRU and Board member is responsible for ensuring that her/his conduct demonstrates trust, respect, integrity and fairness towards our learners, each other and the communities we serve.
The requirement to understand and to comply with these standards of conduct is a condition of employment. Employees who fail to comply with these standards may be subject to disciplinary action up to and including dismissal.
Application of the Code of Conduct:
This Code of Conduct applies to every employee of RRU (full-time, part-time, temporary or casual employee). The Code of Conduct also applies to every Board of Governor of the university.
Conflict of Interest – Principles:
Conflict of interest is a breach of an obligation to the university that has the effect or intention of advancing one’s own interest or the interests of others in a way detrimental to the interests or potentially harmful to the integrity or fundamental mission of the university.
In the event of a potential conflict of interest or perceived conflict of interest, it is the employee or Board member’s responsibility to disclose this conflict to his/her supervisor. In the case of the President, such disclosure must be made to the Board Chairperson. In the case of a Board member, such disclosure must be made to the Board Chairperson. In the case of the Board Chairperson, such disclosure must be made to the Minister responsible for the Public Sector Employers Act.
Such disclosure should occur immediately to ensure that direction is provided to the employee or Board member so that a conflict of interest can be avoided or that actions are taken to remove someone in a conflict of interest. Such disclosure must be in writing.
While the university recognizes that employees have a right to be involved in personal relationships and community and business activities, all employees of RRU shall conduct themselves in a manner that will avoid conflict of interest situations.
While employed by the university, employees shall:
- During ordinary working hours devote their full time, energy and ability to employment of the university, and shall not during any such time engage in any other business or activity;
- Not engage or become connected in any business undertaking for gain without prior written approval, specifying the specific terms and conditions of such undertaking, from the appropriate Vice-President or his/her delegate;
- Identify any research or intellectual property that is in progress that the employee brings with them to the university;
- Agree that any research or intellectual property, including but not limited to software, audio visual materials and/or instructional materials, that is developed while in the employ of the university will be the right of the university to benefit from, reimbursing the employee as it sees fit, and will remain the property of the university if the employee leaves its employ; and
- Avoid any situation in which any actual, potential or perceived conflict of interest may arise, and to report to his/her supervisor any such actual, potential or perceived conflict of interest of which they may become aware.
Board Member Expectations:
As the trustees of the university, Governors are expected to, at all times:
- Act with integrity, independence and good faith, and to maintain the highest ethical standards;
- Comply with the Board’s Code of Conduct and Conflict of Interest Guidelines;
- Not use for personal benefit or advantage any information acquired in the conduct of your service as a Governor;
- Observe the confidentiality of information discussed in closed and in camera sessions and in committees established by the Board;
- Be bound by the majority and rules of dissent; and
- Notwithstanding that members are nominated / elected / appointed by different constituencies, always serve the best interests of the university as a whole.
Governors are expected to exercise a duty of care in discharging their responsibilities. They are expected to:
- Understand the university, its legislative framework, operating environment and financial condition;
- Attend and participate in Board meetings, prepare for Board meetings, maintain a strong attendance record, and be available to serve on at least one board committee;
- Demonstrate openness to others’ opinions and a willingness to listen, contribute constructively to debate, be willing to raise tough questions in a manner that encourages open discussion, be an active, energetic and probing board member exercising critical judgement on policy and fiscal matters;
- Participate in Board orientation and continuing Board development; and
- Participate in periodic assessments of Board performance.
Conflict of Interest – Employment Restrictions:
As a condition of accepting employment with RRU, each management contract contains provisions as set out below addressing non-competition, non-solicitation and injunctive relief provisions. Employees are encouraged to review the offer of employment and direct any questions he/she may have, prior to signing the contract, to the Human Resources Department.
The Executive covenants and agrees that during the term of his/her employment with the university, he/she shall not, except as an employee of the university, whether individually or in partnership or jointly or in conjunction with any person or persons, as principal, agent, shareholder, officer, employee or in any other manner whatsoever, carry on any business, or be engaged or employed in any business, within the province of British Columbia, that offers and/or provides services in competition with the university.
The Executive covenants and agrees that during the term of his/her employment with the university and for a period of twelve (12) months following its termination, regardless of the reason for such termination or the party effecting it, he/she shall not, except as an employee of the university, whether individually or in partnership or jointly or in conjunction with any person or persons, as principal, agent, shareholder, officer, employee or in any other manner whatsoever: (a) accept employment with related entities for a twelve (12) month period; (b) solicit any client to transfer its business from the university to any other person; (c) seek in any way to persuade or entice any employee of the university to leave that employment; or (d) be a party to or abet any such action.
The Executive acknowledges and agrees that a breach by the Executive of any of the covenants of this Agreement would result in irreparable harm to the university that could not adequately be compensated by way of a damage award. The Executive agrees that in the event of any such breach, in addition to all other remedies available to the university at law or in equity, the university shall be entitled as a matter of right to obtain from a court of competent jurisdiction such relief by way of restraining order, injunction, decree or otherwise as may be appropriate to ensure compliance with the provisions.
Conflict of Interest – Acceptance of Gifts, Entertainment, Benefits & Favors:
The giving and receiving of gifts (goods or services) may occur within the university’s operations, particularly when dealing with external and international partners. However, the acceptance of gifts for personal use from people or companies who do business or who may potentially do business with RRU could impede the objectivity of employees or Board members and create a conflicting obligation to that person or company contrary to the obligation of employees or Board members of RRU.
The following parameters apply in situations of giving or receiving gifts:
- Any employee or Board member who receives a gift of goods or services with a significant value (more than $100) shall deliver the goods to the Office of the President and the goods shall become the property of the university.
- The reporting of such a gift of goods or services should occur at the earliest possible opportunity upon receipt of the gift.
- An employee or Board member who accepts a gift of significant value while travelling outside of Canada should, upon returning to Canada, pay the applicable duty, and the university will reimburse the employee of Board member for such duty.
- The goods accumulated by the university under this Policy will be disposed of, from time to time, as determined by the university in its discretion.
- Tokens of appreciation of insignificant value (less than $100) may be accepted at the discretion of the individual. However, any employee or Board member who receives gifts during any fiscal year (April 1 to March 31) with an aggregate value of over $100 from any one source must report each gift along with its estimated value to the Office of the President.
- An employee or Board member of RRU shall not accept a gift of money under any circumstance.
The following parameters apply in situations of offers of entertainment/favors:
- Any employee or Board member who receives an offer of entertainment, or a favor from people of companies that do business with the university must recognize that the acceptance of such an offer may be a conflict of interest or a perceived conflict of interest if the offer were accepted.
- Insignificant offers with a value of less than $100 are at the discretion of the employee or Board member.
- Any concerns with accepting such an offer should be discussed in advance with the employee’s supervisor (or with the Board Chair in the case of a RRU Board member).
Outside Interests / Impartiality
The University recognizes that employees have the right to be associated with political parties and associated activities. However, employees who engage in political campaigns must do so in their individual capacity and without support or representation from the university and must not bring partisan politics into the workplace.
The university has established a policy with regards to these expectations and it is the responsibility of an employee to understand this policy and seek clarification if there is any question with regard to his/her political activities.
Workplace Conduct: Employment Matters:
In the event that a relative of a current RRU employee or a relative of a current Board member be offered employment with the university, the following code of conduct is required:
- Should an offer of employment be extended to a relative of a current university employee, it is the responsibility of both the current university employee and the family member (potential new employee) to fully disclose their relationship to the President/Vice-President and department Manager before the offer of employment is accepted.
- Should no actual or potential conflict of interest exist between the staffing positions to be held by the family member, reasons should be documented in writing. This written submission will be included in the department personnel file for each affected employee.
- This written submission as well as a proposal prepared by the Manager involved in the potential hiring and supervision of the employment relationship will form the basis of a review to be conducted by the President/Vice-President.
- Approval of the employment relationship may or may not be granted. Fair and equitable application of this policy is expected of all parties involved in the review process
Workplace Conduct – Respectful Workplace:
The university strives for a respectful, fair and productive work environment for all its employees and all those that work directly with our employees on campus. Thus RRU is committed to providing a work environment free of bullying and harassment and discrimination; such behaviors will not be accepted or tolerated. All employees will be treated in a fair and respectful manner.
The university has established a policy, investigation procedures and reporting mechanism to address any allegations of bullying, harassment or discrimination.
Workplace Conduct – Health and Safety:
There is nothing more important than the health and safety of our employees, learners, and the suppliers and contractors that we do business with. Through an active Joint Occupational Health and Safety Committee, training and supervisory due diligence, the university strives to ensure a safe and healthy workplace.
One component of health and safety is the respectful treatment of all employees and learners in providing a safe campus in which to work and study. All employees may expect and have the responsibility to contribute to a safe workplace and campus. Violence in the workplace is unacceptable.
Employees must report any incident of violence immediately to his/her supervisor or to Human Resources. An employee who becomes aware of a threat must report that threat if there is reasonable cause to believe that the threat poses a risk of harm. Any incident or threat of violence in the workplace must be addressed immediately.
The university ensures that all health and safety legislation is understood and adhered to and every employee is expected to conduct themselves in accordance with all relevant health and safety legislation.
Use of University Property:
All records created or received by the university are considered government records and must be managed in accordance the Freedom of Information and Protection of Privacy Act and with the BC Document Disposal Act regardless of their form or medium. The university retains and disposes of records in accordance with the approved retention and disposition schedules.
As an employee of RRU it is critically important for each employee to understand and maintain confidentiality of university records including both employee records and student records.
Any question with regard to the storage and/or retention of records may be directed to the university’s FOIPOP Officer.Freedom of Information and Protection of Privacy (FOIPOP):
RRU ensures compliance with the Freedom of Information and Protection of Privacy Act. Any questions or information inquiries with regard to FOIPOP may be directed to the university’s FOIPOP Officer.
A comprehensive policy and procedures with regard to intellectual property is established in both Board policy and within the RRU Faculty Association collective agreement. The overall purpose of an intellectual property policy is to:
- Provide a supportive climate and incentives for intellectual and creative development, Innovation, and entrepreneurship by members of the RRU community, including students;
- Acknowledge that RRU has an obligation, within a framework of respect for copyright and patent principles, to disseminate the products of scholarly activity to benefit the creators, the institution, and the public;
- Provide a framework for effective development and utilization of discoveries for the economic benefit of British Columbia and Canada which would be in the interests of the public and RRU;
- Provide the potential for gaining funds and other resources to be used to promote and aid research and creative activities, employee and student entrepreneurism, and technology transfer at RRU;
- Ensure RRU meets its obligations to funding sponsors and assist RRU members in fulfilling the terms of grants or contracts with respect to intellectual property;
- Provide safeguards for the equitable protection and disposition of proprietary rights and recognize and uphold the principles of scholarly integrity and academic freedom in the commercialization of IP for the protection of RRU and its community; and to
- Establish a set of procedures to address ownership, disclosure, publication, commercialization, and disposition and sharing of revenues associated with RRU IP, and when such sharing is in dispute, provide an effective dispute resolution mechanism.
Protection of General Corporate Information:
Confidentiality While Employed with RRU:
All confidential information heard, created or accumulated by contractors and employees of RRU must be used or reviewed on a strict need-to-know basis in the performance of contract or job functions, and must not be disclosed to anyone other than persons authorized to receive it, both during a contract or employment period and beyond it. Recorded information in all formats is covered by this policy.
Confidential information includes, among other examples:
- Business plans; draft reports; research results; legal opinions; etc. It also includes the personal information of identifiable individuals. Personal information is covered by the provincial Freedom of Information and Protection of Privacy Act (FOIPOP Act) in addition to this policy.
- Examples are: learner enrolment information; contact information of learners, prospective learners, contractors, employees, alumni, donors, visitors and other members of the public; photographs of all individuals; educational history of learners; birth dates of any individuals; personal opinions as expressed in learner essays and discussions; work history of contractors and employees.
- Personal information must be collected, recorded, corrected, accessed, altered, used, disclosed, retained and removed only in accordance with the Act and university guidelines, and must be maintained in a secure manner.
- Contractors and employees who are uncertain whether information is confidential must check with their supervisors and any other appropriate authorities before using and disclosing it. Any suspected violation of the Act or this policy must be reported to appropriate university officials, including the Registrar if learner data is involved.
- Individuals failing to comply with this policy may be subject to forms of disciplinary/other action up to, and including, dismissal / termination of employment. They may also be subject to legal action following their employment with the university.
RRU is critically dependent on its information, information systems and infrastructure. The appropriate use of technology at RRU is a strategic advantage. Loss, unavailability, unreliability and inappropriate disclosure of information constitute serious risk.
The university will take appropriate measures, with the cooperation of all computer network users, to ensure the integrity of the RRU networks and to mitigate the risks and losses associated with security threats to RRU networks and resources, in accordance with administrative policies, standards and procedures established by the President for the purpose of protecting information.
RRU employees are responsible for the appropriate use of confidential information while employed by the university and after leaving the employ of RRU. Each contract of employment contains this standard provision with regard to the confidentiality of information both during and post-employment with the university:
- “Confidential Information” means information disclosed to, used by, developed by, or made known to the Manager in the course of his/her employment with the university which is not generally known by persons outside the University including, but not limited to, information (printed, electronic or otherwise) pertaining to the university’s past, present, future and contemplated assets, operations, services, facilities, equipment, strategies, personnel, finances, routines, policies and procedures.
- The Manager acknowledges that he/she will have access to and be entrusted with Confidential Information in the course of his/her employment with the university, and that the university would be irreparably harmed if such Confidential Information were disclosed to, or used by, any person outside the University’s employ.
- The Manager acknowledges and agrees that the right to maintain the absolute secrecy of the Confidential Information is a proprietary right which the university is entitled to protect.
- The Manager covenants and agrees that he/she will not, except as required by law, either during the term of his/her employment under this Agreement or at any time thereafter, directly or indirectly, by any means whatsoever, divulge, furnish, provide access to, or use for any purpose other than the purposes of the University, any Confidential Information.
Responsibilities: Commitment and Compliance:
Every employee or Board member of RRU must fully comply at all times with both the letter and the spirit of all laws applicable to employment or Board appointment. As a publically funded university with a primary mission to serve its students, employees and Board members must avoid any situation that could be perceived as improper or indicate a casual attitude to compliance. Employees or Board members must never commit or condone an illegal act or counsel another employee, learner, contractor or consultant to do so. As a public institution, the actions of our employees and Board members are subject to public scrutiny and the reasonable expectation of the public that we will manage the university assets to the highest ethical standard.
It is the responsibility of each employee and Board member of RRU to read and understand this policy and adhere to the policy.
It is the responsibility of the President to ensure that administrative policies, standards, procedures, personnel and processes are in place to affect this policy.
It is the responsibility of RRU’s Board of Governors to enforce this policy and ensure that both the content and spirit of the policy is adhered to.
Accordingly, employees or Board members who engage in inappropriate conduct may be subject to disciplinary action, up to and including termination of employment or removal from the Board.
An allegation of ethical misconduct or fraud shall be sent to the Chair of the Board’s Finance and Audit Committee.
The Board of Governors shall ensure that:
- Upon receiving an allegation of ethical misconduct or fraud in the university, it shall investigate;
- Ensure that the university has appropriate and effective procedures for dealing discreetly with disclosures of ethical misconduct;
- Provide an avenue for receiving and acting upon allegations of retribution against whistleblowers; and
- Review reports from the Finance and Audit Committee on complaints received under this policy and actions taken.
RRU is committed to maintaining the highest standards of ethical conduct. It is the responsibility of each employee, learner or Board member to immediately report any alleged ethical misconduct or fraud.
Employees, learners and volunteers are often in the best position to observe ethical misconduct or abuse of public trust because of their proximity to day-to-day university operations. The university relies on these individuals to report such activities so that it can take prompt corrective action.
The university will protect all individuals who take steps to expose wrongdoing by prohibiting harassment, threats, retaliation or discrimination against them.
A Code of Conduct Policy cannot reasonably cover every circumstance that may arise in the university. In the event that a conflict of interest or allegation of a breach of conduct arise that is not covered by this policy, the university reserves the right to act reasonably and in accordance with the overall spirit and intent of this policy to ensure the highest standards of ethical conduct.
In the event that any provision within this policy is in conflict with existing collective agreement language, the latter will prevail.