Code of Conduct

Introduction 

As members of the Brown University community, we are responsible for sustaining the highest ethical standards of the University, and of the broader community in which we function. The University values integrity, honesty and fairness, and strives to integrate these values into its teaching, research and business activities.

                                           

Policy Statement 

Brown University Code of Conduct                                                                                                                                                                                                                       

1.      Introduction and Purpose

As members of the Brown University community, we are responsible for sustaining the highest ethical standards of the University, and of the broader community in which we function. The University values integrity, honesty and fairness, and strives to integrate these values into its teaching, research and business activities.

a.      What Is the Code of Conduct?

The Code of Conduct (Code), is a shared statement of our commitment to upholding the ethical, professional and legal standards we use as the basis for our daily and long-term decisions and actions.

b.      Why Do We Have the Code of Conduct?

We all must be cognizant of, and comply with, the relevant policies, standards, laws and regulations that guide our work. We are each individually accountable for our own actions and, as members of the University community, are collectively accountable for upholding these standards of behavior and for compliance with all applicable laws and policies.

c.       Who Needs to Follow the Code of Conduct?

The Code applies to all members of the Brown community. For purposes of this Code, Brown community members are: Corporation members, faculty, undergraduates, graduate and medical students, staff, volunteers and visiting scholars.

d.      What Are the Code of Conduct Certification Requirements?

Annually, as a member of the Brown University community, you will read and sign the Annual Code of Conduct Compliance Certification attesting your commitment to adhere to the Brown University Code of Conduct. Adherence to this Code also makes us responsible for bringing suspected violations of applicable standards, policies, laws or regulations to the attention of the appropriate cognizant office. Raising such concerns is a service to the University and does not jeopardize one’s position or employment. Confirmed violations will result in appropriate disciplinary action up to and including termination from employment or other relationships with the University. In some circumstances, civil and criminal charges and penalties may apply.

2.     We Uphold Standards of Integrity and Quality

Brown University recognizes that it must earn and maintain a reputation for integrity that includes, but is not limited to, compliance with laws and regulations and its contractual obligations. Even the appearance of misconduct or impropriety can be very damaging to the University. The University must strive at all times in its dealings, including its business activities, to maintain the Principles of the Brown University Community and the highest standards of quality and integrity.

a.      What are the Principles of the Brown University Community?

We, as members of the Brown University community, are dedicated to supporting and maintaining a scholarly community in which all share in the common enterprise of learning. As a central aim, Brown University promotes intellectual inquiry through vigorous discourse, both oral and written.

The fundamental principles that must necessarily undergird this aim include respect for the integrity of the academic process; individual integrity and self-respect; respect for the freedoms and privileges of others; and respect for University resources. In becoming part of Brown University, we accept the rights and responsibilities of membership in the University’s academic and social community, and assume the responsibility to uphold the University’s principles.

Standards of Integrity:

  • Respect for the Integrity of the Academic Process 

The rights and responsibilities that accompany academic freedom are at the heart of the intellectual purposes of the University. Our conduct as community members should protect and promote the University’s pursuit of its academic mission. We are all, therefore, expected to conduct ourselves with integrity in our learning, teaching, and research, and in the ways in which we manage and support those endeavors.

  • Individual Integrity 

In order to ensure that the University can dedicate itself fully to its academic and educational vision, it is expected that an individual’s personal integrity will be reflected not only in honest and responsible actions, but also in a willingness to offer direction to others whose actions may be harmful to themselves or the community. The University expects that members of the Brown community will be truthful and forthright. The University also expects that community members will not engage in behavior that endangers their own sustained effectiveness or that has serious ramifications for their own or others’ safety, welfare, academic well-being or professional obligations.

  • Respect for the Freedoms and Privileges of Others

We strive for a sense of community in which the individual growth of all members is advanced through the cultivation of mutual respect, tolerance and understanding. Brown University values and encourages individuality while also affirming the need to maintain a climate in which the activities of academic and community life may be freely pursued. A socially responsible community provides a structure within which individual freedoms may flourish without threatening the privileges or freedoms of other individuals or groups.

  • Statement of Non-Discrimination

Brown University does not discriminate on the basis of sex, race, color, religion, age, disability, status as a veteran, national or ethnic origin, sexual orientation, gender identity, gender expression or any other category protected by applicable law, in the administration of its educational policies, admission policies, scholarship and loan programs, or other school-administered programs. The University is committed to honest, open and equitable engagement with racial, religious, gender, ethnic, sexual orientation and other differences. The University seeks to promote an environment that in its diversity is integral to the academic, educational and community purposes of the institution.

3.     We Maintain the Confidentiality and Privacy of Information

As a member of the Brown University community, you receive and produce various types of confidential, proprietary and private information on behalf of the University. Access to confidential information should be limited to those who require it to discharge their duties. When you receive confidential information you have a responsibility to maintain and safeguard this information and use it with consideration and ethical regard for others. You must not divulge non-public information regarding the University to an outside party, or to those within the University, except for legitimate business, research or academic purposes. You will not directly exchange with another institution University information that includes prospective tuition, financial aid or salary plans.

Circumventing or attempting to circumvent restrictions on the use and dissemination of confidential information is considered a serious offense. Your obligations regarding confidential information continue after your relationship with the University ends. It is imperative that you comply with all laws, third-party agreements and University policies and principles pertaining to the use, protection and disclosure of confidential information. Some departments, based upon the nature of their responsibilities, have established stricter standards for confidentiality. In these cases, the stricter departmental standards will apply.

a.      Computing Resources

The computing resources at Brown University support its educational, instructional, research and administrative activities. Use of these computing resources is a privilege that is extended to you as a member of the Brown community. Your use of these services and facilities may allow you to have access to valuable University resources, to sensitive data and to internal and external networks. Consequently, it is important for you to behave in a responsible, ethical and legal manner. The Acceptable Use Policy establishes specific requirements for your use of all computing and network resources at Brown University.

4.     We Avoid or Disclose Conflict of Interest and Commitment

All decisions and actions taken by you, as a member of the Brown community, in the conduct of University business, will be made in a manner that promotes the best interests of Brown University. You have an obligation to address both the substance and the appearance of conflicts of interest and commitment and, if they arise, to disclose them to the appropriate University representative and withdraw from debate, voting or other decision-making processes where a conflict of interest exists or might arise.

The Brown University Conflict of Interest and Commitment Policy and its related guidelines apply to all members of the Brown community. The University recognizes that members of the Brown community perform different functions on Brown’s behalf. A particular outside interest, activity or relationship that is a conflict for you, may not be a conflict for other members due to their different areas or levels of influence on University business. Therefore, this means that while we are all subject to the general policy, certain members of the community may be subject to additional policies, procedures and/or disclosure requirements. For example, if you are an officer of instruction and research, you are subject to the Conflict of Interest Policy for Officers of Instruction and Research, a policy specific to the educational and research activities of faculty and researchers. Also, certain administrative positions and/or units may be subject to additional guidelines, procedures, and/or disclosure requirements, consistent with the general policy.

Brown defines conflict of interest and conflict of commitment as:

a.      Conflict of Interest

A conflict of interest may take many forms but arises when you, as a member of the Brown community, might be able to use the authority of your Brown position to:

  • Influence the University’s business decisions in ways to give improper advantage or financial benefit to yourself, a family member or associate, or;
  • Obtain for yourself, a family member or an associate a financial benefit beyond the compensation you are authorized to receive for performing your University responsibilities.

b.      Conflict of Commitment

A conflict of commitment occurs when a commitment to activities outside of your University responsibilities interferes with your capacity to meet your University responsibilities.

It is recognized that some of your outside service and professional responsibilities can and do benefit Brown. If you are a Corporation member, your outside responsibilities do not ordinarily pose conflicts of commitment because your service to the University is uncompensated. If you are a faculty member, limits on your outside activities are defined in the Brown University Conflict of Interest and Commitment Policy and the  Conflict of Interest and Commitment Policy for Officers of Instruction and Research. For administrative officers and members of the staff, your time allowed for service to other organizations depends on your job responsibilities and your supervisor's expectations for your level of involvement with professional and community organizations, and is defined in the Brown University Conflict of Interest and Commitment Policy.

As a member of the Brown community, you must disclose any outside activity that is, or may be perceived to be, a conflict of commitment so that these activities can be managed properly. 

5.     We Respect University Resources  

As members of the Brown University community, we respect and conserve the general resources and physical property of the University. Such resources are assets in which community members have a vested interest, as these resources specifically support the University’s mission.

University resources include, but are not limited to University equipment, communications systems and solutions; technology; software and service licensing; procurement tools; and databases containing personal information. It also includes the time and effort of employees, students and others at Brown; and those resources purchased/paid with University funds, including funds received by Brown through government or other external funding sources.

University resources are reserved for business purpose use on behalf of the University. The use of University resources for personal gain or advantage, or for the benefit or gain of any other individual or outside entity (including organizations in which you have a vested interest) is strictly prohibited. You may not use the University name and/or visual identity (logos and associated word marks), other than in the context of your Brown responsibilities. Any personal use of University resources must be in accordance with published limitations; should not incur any additional expense to the University; should not interfere with an employee’s obligation to carry out University duties in a timely and effective manner; must in no way undermine official University business; must not involve activities that are unlawful or inappropriate; and should never be used in a way that seems to connote Brown University sponsorship of personal ventures.

Employees should consult with their supervisors in advance if they have any questions about appropriateness of certain practices. However, a supervisor’s decision cannot circumvent existing policies and procedures established by the University.

6.     We Treat Each Other with Respect

Brown University is an institution dedicated to the pursuit of excellence and facilitation of an environment that fosters this goal. Central to this institutional commitment is the principle of treating each community member fairly and with respect. The University prohibits discrimination and harassment and provides equal opportunities for all community members and applicants. We, as members of the Brown University community, share a commitment to performing our duties in accordance with the highest standards of ethics and in compliance with University policies and all applicable laws and regulations.

The Principles of the Brown University Community (outlined in Section 2 of this Code) are values that hold for the entire University community. Specific standards of conduct and procedures for redress of violations of those standards for various members of the community can be found in the following University documents:

a.      All Students, including Graduate and Medical Students 

The standards and procedures for all students may be found in the Academic Code, and Code of Student Conduct. All students are expected to read the Academic Code and the Code of Student Conduct, be familiar with the Principles of the Brown University Community and sign a statement acknowledging their responsibility for the codes.

b.      Graduate Students

Graduate students should also refer to the Academic and Student Conduct Codes: Graduate Student Edition, published by the Graduate School.

c.       Medical Students

Medical students should also refer to the Medical Student Standards of Behavior in the Medical Student Handbook, set forth by the Warren Alpert Medical School.

d.      Faculty

Policies and procedures regarding faculty rights and responsibilities are found in the Handbook of Academic Administration, which puts into practice the principles outlined in the document Faculty Rules and Regulations.

e.       Staff

Policies and procedures guiding staff conduct may be found on the Brown  University’s Administrative Policies website.

f.        Corporation Members

Members of the Corporation carry out their responsibilities and functions in accordance with the Brown University Charter and the Statutes of the Corporation.

g.      All Community Members

Brown University policy statements on discrimination and harassment reflect Brown’s commitment to creating and maintaining educational, working and living environments that are free of any unlawful discrimination. The University recognizes its legal obligations to pursue that same goal under applicable Federal and State statues, which include Title IX, Title VI and Title VII of the Civil Rights Act of 1964.

  • Title IX: Title IX prohibits discrimination on the basis of sex in education programs and activities receiving Federal financial assistance. Policies and procedures related to Title IX and Gender Equity may be found in the Sexual and Gender-Based Harassment, Sexual Violence, Relationship and Interpersonal Violence and Stalking Policy.
  • Title VI: Title VI prohibits discrimination on the basis of race, color or national origin under any program or activity receiving federal financial assistance. Employment discrimination is covered by Title VI if the primary objective of the financial assistance is the provision of employment or where employment discrimination causes discrimination in providing services under such programs.
  • Title VII: Title VII prohibits discrimination in employment on the basis of race, color, religion, sex or national origin. In certain instances, differential treatment is allowed for religion, sex or national origin if it is a bona fide occupational qualification. Sexual harassment is also prohibited under this law, as are all forms of harassment based on membership in a protected class.

7.      We Maintain and Report Complete and Accurate Financial Information

We will adhere to University policy for all University financial accounts, reports, expense reimbursements, time submissions and other transactions and documents. We will maintain accurate books and records, and University financial reports will reflect complete and accurate information.

8.     We Comply with the Law

Brown University is committed to the highest standards of ethical and professional conduct. This means, we conduct business on behalf of the University adhering to these standards in the performance of our duties. It is the responsibility of each individual – whether a faculty or staff member, student employee or volunteer acting on behalf of the University – to comply with legal and regulatory requirements, policies and procedures that apply to an individual’s particular duties. If you are a manager or supervisor, you are also responsible for teaching and monitoring compliance. If you have a question pertaining to interpretation or applicability of a policy, you can contact the individual who has oversight of, or responsibility for, the policy. If you are a senior officer of the University, you may consult, as needed, with the Office of General Counsel regarding unresolved questions and/or interpretation of laws and regulations.

a.      Contractual Obligations 

Accepting an agreement or contract, including sponsored project funding, may create a legal obligation on the part of Brown University. We must comply with the terms and conditions of the agreement as well as applicable laws and regulations. Therefore, only if you have authority delegated by an appropriate University official can you enter into agreements or contracts on behalf of the University; otherwise, you cannot sign an agreement.

b.      Environmental Health and Safety, including Workplace Health and Safety

Members of the University community have a shared responsibility to ensure a safe workplace and to protect the health and safety of all students, faculty, staff and visitors. This means you adhere to good health and safety policies and practices; comply with all environmental health and safety laws, regulations and related University policies; attend required training; and report unsafe conditions, equipment or practices to University officials.

c.       Non-University Professional Standards

Some professions and disciplines represented at the University are governed by standards and codes specific to their profession (such as attorneys, certified public accountants and medical doctors). These professional standards generally advance the quality of the profession and/or discipline by developing codes of ethics, conduct and professional responsibility and standards to guide their members. If you belong to such organizations, you are expected to adhere to University policies and this Code of Conduct, in addition to any professional standards. If you believe there is a conflict between a professional standard and University policy, you should discuss the concern with your supervisor.

d.      Academic Policies

Academic policies are located in the Academic Code, and Code of Student Conduct; Graduate Academic Code and Student Conduct Code; as well as the Handbook of Academic of Administration.

e.       Guidelines for Political Activities

Brown encourages all members of its community to be active and informed citizens. We support campus-based activities and programs that enhance the individual capacity of members of the Brown community to execute their prerogatives as citizens. However, as a non-profit, private institution of higher education whose activities are regulated in part by Section 501(c)(3) of the Internal Revenue Service (IRS) Internal Revenue Code, we are prohibited from participating in political campaigns for candidates or ballot initiatives, and are restricted in conducting lobbying activities. Violation of IRS regulations could have serious ramifications for the University, including loss of its tax-exempt status.

Therefore, we provide Guidelines for Political Activities that detail the permitted use and restrictions of University facilities and resources for partisan, politically related activity on campus by students or employees. These guidelines cannot address every potential situation. If you have questions regarding these guidelines, you can contact the Office of Government and Community Relations or, if related to student-sponsored activities, the Student Activities Office.

f.        Communication Policies

Brown University is governed by federal laws and the laws of Rhode Island pertaining to rights and permissions affecting communications produced by any member of the Brown community. Privacy laws require permissions for the use of an individual’s image or likeness for marketing or promotional use. Copyright and trademark laws outline standards for securing permission for incorporating forms of intellectual property that include: video, photography, design, written works and audio recording. Individuals or units at Brown that violate these laws in their communications may be subject to individual or joint liability. Brown outlines policies on image use and copyright that apply to all members of the Brown community to limit institutional and personal liability.

g.      Guidelines for Promotional Activities

Brown University encourages positive relationships with its partners, contractors, vendors and stakeholders. However, members of the Brown faculty or staff cannot, in their capacity as University employees or representatives, endorse non-affiliated, for-profit business or operations. Questions about participating in press releases, testimonials, and other forms of promotional activities should be addressed to the Office of University Communications.

9.     We Speak Up and Appropriately Report Suspected Violations

Brown University is committed to the highest standards of ethical conduct and integrity in all areas of its mission. We, as members of the Brown University community, should report suspected violations of applicable laws, regulations, government contracts and grant requirements, and of this Code of Conduct. This reporting should normally be made initially through standard management channels, beginning with your immediate supervisor, instructor or advisor. If for any reason it is not appropriate for you to report suspected violations to your immediate supervisor (e.g., the suspected violation is by the supervisor), you may go to a higher level of management or contact Brown University’s chief University auditor. We expect that your report will be made in a good faith effort to address legitimate issues needing correction, or to otherwise provide reliable information. If you are reporting a suspected violation in good faith, it is protected under the Rhode Island Whistleblowers’ Protection Act Section 28-50, which prohibits retaliation against employees for disclosing a violation or noncompliance with laws, rules or regulations. 

a.      Suspected Fiscal Misconduct

All University employees, including student employees, are responsible for the proper conduct and handling of any University resource or fiscal matter entrusted to them, in accordance with laws, regulations, University policies and other expectation of ethical business conduct. The University’s Fiscal Misconduct Policy requires employees, including student employees, to promptly report to the chief University auditor any actual or suspected fiscal misconduct, whether by members of the University community or by persons outside the University involving University resources. If you instead report fiscal misconduct to a supervisor, chairperson, director, dean, vice president or another responsible person, that individual must immediately notify the chief University auditor.

b.      Anonymous and Confidential Reporting

Brown community members (including faculty and staff) can report concerns through the University’s anonymous and confidential Ethics And Compliance Reporting System (EARS). EARS is hosted by a third-party service provider and is available 24 hours a day, seven days a week, 365 days a year, online at http://www.Brown.ethicspoint.com,  or via a toll-free telephone number at (877) 318-9184.

Through EARS, you can report activities that may involve unethical or otherwise inappropriate activity or behavior in violation of University established policies in the areas of:  accounting and finance; information and technology; research; and risk and safety matters. Issues related to areas not specifically mentioned should be reported through existing University channels.

Once an EARS report is received, appropriate University officials investigate the report  following the processes outlined in the University’s Fiscal Misconduct Policy. The chief University auditor has the primary responsibility for coordinating the initial assessment of the report. It should be noted that the more information given in an EARS report, the easier it is to investigate it.

c.       Cooperation

As a member of the Brown University community, you will cooperate fully with any audit, inquiry or investigation undertaken at Brown’s direction by its attorneys, investigators, internal auditors or independent public accountants.

10. Whom Do We Contact with Questions?

You can direct questions regarding the intent or applicability of this Code of Conduct to Barbara Chernow, executive vice president for finance and administration, or Russell Carey, executive vice president for planning and policy.

Policy Owner
Approved by 
Executive Vice President of Planning and Policy & Executive Vice President of Finance and Administration
Revision Date:  Thu, 2017-05-18 14:40