A. General Statement of Conduct
1. Fairness, integrity, respect
The University of Iowa values fairness, integrity, and respect, and strives to integrate these values into its business practices. All faculty, staff, students, and administrators are expected to act at all times with fairness, integrity, and respect for others. This standard applies to interactions with the public, contractors, students, and coworkers.
As an educational institution, the University values self-expression. Faculty and staff members are responsible for promoting a spirit of respect that reflects a commitment to tolerance and diverse points of view.
For more information, see the following:
University of Iowa Community Policies on Human Rights, Affirmative Action, and Equal Employment Opportunity (Chapters 1-11).
2. Compliance with law and policy
University of Iowa employees are expected to comply with all applicable laws, rules, and regulations of the state and federal government, as well as all policies of the University and of the Board of Regents (including the Regents Code of Fiduciary and Business Conduct). This expectation derives from our employment relationship with the University: as employees, we are the University when it comes to complying with law or policy. As our employer, the University is liable for acts we perform on its behalf that are within the scope of our employment. When we violate the law as employees, it is the University that is held responsible and the University’s assets that are exposed to liability.
For more information, see the University’s Policy on Ethics and Responsibilities for University of Iowa Staff.
B. Objectivity in Decision Making
1. Conflicts of interest relating to business activities
As members of the University community, many of us have opportunities to develop relationships with outside entities and to engage in other outside activities that enhance our professional competence. Such relationships may give rise to various forms of conflicts of interest that call into question our ability to be objective in carrying out our University obligations. In general, the University requires that such conflicts either be avoided where possible or disclosed and managed.
The University has a general Conflicts of Commitment and Interest Policy that addresses conflicts of commitment (outside activities that interfere/appear to interfere with fulfillment of one’s obligations to the University), conflicts of interest in research, conflicts of interest in the workplace, and other situations relating to conflicts of interest discussed in more detail below.
Iowa law and policies of the Board of Regents govern conflicts of interest that may arise when paid employees* of the University engage in business transactions with the University. A University employee may engage in such transactions only after disclosing the possible conflict of interest and obtaining approval from the Board of Regents. In the purchasing context, such conflicts may arise when a University employee participating in a purchasing decision has an interest in or relationship with the prospective vendor. For example, a conflict may exist where the employee’s spouse/partner or minor child is employed by the vendor, or where the employee has a close personal relationship or a partnership or other commercial relationship with the vendor. In such cases, employees should disclose potential conflicts of interest through the Purchasing Department’s vendor application process. The disclosure form may be found at on the Purchasing Department's site.
*”Employee” is defined to include also the employee's spouse and minor children, and any firm of which any of those persons is a partner or sole proprietor, as well as any corporation of which any of those persons holds five percent or more stock either directly or indirectly.
This information is taken from the University’s Policy on Conflicts of Interest in Purchasing as well as the Policy on Purchases from University Faculty or Staff.
See also the following:
c. Personal interest in contracts
Iowa law prohibits state employees from having a personal interest in public contracts. In our context, this means that University employees (as well as members of their immediate families) cannot be interested, either directly or indirectly, in any contract to furnish any kind of services or materials to the University. Such arrangements are allowable only where the Purchasing Department has determined that the services or materials to be provided are either unique or otherwise beneficial to the University in comparison to other available sources of the services. In addition, University purchases from University employees exceeding $1,000 for one transaction or $2,000 in one year must be approved by the Board of Regents.
For more information, see the University’s Policy on Purchases from University Faculty or Staff.
See also the following:
2. Undue influence: giving and receiving gifts
University employees, and members of their immediate families, are prohibited from giving or receiving “gifts” from “restricted donors” as both those terms are defined in Iowa law. In general, a “gift” is anything of value which is received without something of equal value being given in return. Something given in one day and valued at more than $3.00 is included in the legal definition of “gift”. A “restricted donor” is generally someone who may have an interest in influencing the University employee to act in his or her favor on a sale, purchase, lease, or other pending matter. The principle underlying these restrictions is that decisions about University business should be made free from the influence of those who stand to benefit from those decisions.
For more information, see the University’s Policy on Prohibition on Giving and Receiving Gifts.
See also the following:
Related to this policy is the Iowa law provision that University employees may not accept compensation from anyone than the University for performing their University duties.
Honoraria from restricted donors are governed by the same principles as those governing gifts. For more information about receiving honoraria, see the University’s Policy on Giving and Receiving Gifts and these additional resources:
3. Lobbying by public employees and officials
Iowa law prohibits University employees from seeking or accepting loans from lobbyists.* The law also prohibits lobbying by executive or administrative heads of the University for two years after the end of their University service, as well as compensating such persons during that time in connection with any matter in which the person was directly concerned and personally participated during employment. Civil and criminal penalties may be imposed for violating these state law provisions.
*A lobbyist is an individual who 1) receives compensation for the purpose of acting directly to affect legislation or a rule; 2) is a designated representative of an organization which has as its purpose to affect legislation or a rule; 3) represents a government entity for which the person serves or is employed as designated representative for the purpose of affecting legislation or a rule; or 4) lobbies for himself or herself and expends more that $1,000 per calendar year.
For more information, see the University’s Policy on Lobbying Restrictions Applicable to Public Employees and Officials.
See also the following:
Iowa Code §68B.23 at http://www.legis.state.ia.us/IACODE/2003/68B/5A.html
C. Use of University funds and resources for University purposes
1. Use of funds
Travelers must itemize all travel expenses on an official travel expense voucher or procurement card voucher. Original receipts for airfare, rental car, train, hotel, and conference fees, and for any other single expense of $25 or more must be attached to the travel voucher.
Employees traveling on University business, in state or out of state, should secure approval from their department and appropriate University officials to assure that the travel is approved and that funds are available for reimbursement. Each department is responsible for establishing internal approval procedures for travel, defining its signature authority, and informing travelers of these procedures.
The details of the procedures for reimbursement and travel-related payments are outlined in the policy cited below. The policy also sets forth specifics for arranging transportation and working with travel agencies; expense limits for meals, tips, lodging allowances; travel cash advances; and foreign travel.
For more information, see the University’s Policy on Travel Regulations.
b. Purchases for non-University purposes
University employees may purchase through the University only those items for which there is a clear University purpose for incurring the expense. On this basis, employees may not purchase personal or personalized items through the University.
For more information, see the University’s Purchasing Policy (Items Which May Not be Purchased).
2. Use of assets, resources, information, and services for University purpose
a. Grounds, facilities, property
University grounds, facilities, and property are dedicated for use in the advancement of our missions of teaching, research, and service. University employees may not use, or allow to be used, University resources or property for any private purpose or personal gain.
For more information, see:
University of Iowa Policy on Equipment and Personal Property of the University (Private Use of Public Property)
b. Computing resources
All faculty, staff, and students must comply with institutional and external standards governing the use of the University’s information technology resources, including the prohibition against using such resources for private purposes or personal gain. University-supplied technology should be used primarily for University-related educational and administrative purposes. By using University information technology facilities and resources, users agree to abide by all related University policies and procedures, as well as all applicable federal, state, and local law.
For more information, see the University’s Policy on Acceptable Use of Information Technology Resources.
Information is provided in many different forms to University faculty and staff for use in the performance of their employment responsibilities. Such information is a University asset and should be used only for University purposes. In addition, certain types of information possessed by the University may be subject to privacy or confidentiality requirements. Where such requirements exist, University employees are expected to comply with them.
In some circumstances involving electronically-held information, the University requires employees seeking access to such information to accept the terms of a Confidentiality Statement that outlines these principles and the obligations relating to use of the information.
Generally speaking, faculty and staff members should not use University supplies, materials, equipment, or services for non-University activities without first obtaining approval and arranging to pay for the total cost of such use. This restriction derives from the state law prohibiting the use of state resources for private business or personal gain.
For more information, see the University’s Policy on Supplemental Activities and Extra Compensation (Use of University Supplies).
e. University name
The use of the University’s name in certain circumstances may imply that the University has endorsed particular goods or services. For this reason, use of the University’s name for any purpose or activity unrelated to the fulfillment of the missions of the University must receive prior approval from the Vice President of Strategic Communication.
For more information, see the University’s Policy on Use of University Name at http://www.uiowa.edu/~our/opmanual/ii/33.htm.
f. University business opportunities
From time to time, a University employee may have the opportunity to engage in an extramural professional activity either independently of the University (for example, as an independent consultant) or through the University itself (acting in his/her capacity as a UI employee). In such circumstances, the employee is obligated to allow the University to decide whether it wishes to have the activity carried out through the University. The employee may not pursue the activity independently until and unless the University provides a written waiver of its interest in the proposed opportunity. Such waivers may be obtained from the dean of the college (if the employee is appointed within a college) or from the director of the unit in which the employee is appointed.
For more information, see the University’s Policy on Supplemental Activities and Extra Compensation (Usurpation of University Opportunities).
g. Cell phones
University employees are required to obtain departmental approval prior to using University cell phones for University business purposes. Cell phone use for personal business is to be limited to necessary calls that cannot be postponed. All other personal calls must be fully reimbursed. It is the responsibility of the employee’s department, college, or administrative unit to monitor cell phone use and reimbursement in compliance with this policy.
For more information, see the University’s Purchasing Policy (Cellular Phone Policy).
h. Telecommunications and network services
Because these services are provided for University business, University policy regulates personal use of University long distance telephone services and University calling cards. For more information, see the University’s Policy on Information Technology Services (Telecommunications and Network Services).
D. Integrity in the conduct of University business
1. Accounts payable
The University’s Accounts Payable Department is responsible for the auditing and processing of invoices and payments for The University of Iowa. Invoices, credits, vouchers, and payments are processed on line through the Accounts Payable/Purchase Order System. This authority is delegated from the Board of Regents through the President of the University in accordance with the statutes and administrative rules of the State of Iowa and the procedures of the Board of Regents.
The Accounts Payable Department is responsible for auditing and processing accurate and timely payments to vendors and individuals. Transactions processed through this department include vendor invoices, individual reimbursement, freight, Purchasing Cards, prepayments and meeting registrations. The payment process involves application of credit memos, reviewing vendor statements, resolving discrepancies, depositing refund checks, and providing customer service.
University policy regulates the purchase of goods and services from all sources of funds administered by the University. The Purchasing Department administers the procurement of goods and services for all University departments by the authority delegated through the President from the Board of Regents. The Director of Purchasing is vested with sole authority to obligate University funds and is responsible for ensuring compliance with Iowa law and the policies and procedures of the Board of Regents.
The Purchasing Department follows the Code of Ethics of the National Association of Educational Buyers (NAEB), the association serving the purchasing and materials management professionals of higher education and not-for-profit health care organizations.
The University’s various purchasing policies may be viewed at http://www.uiowa.edu/~our/opmanual/v/11.htm#111.
Regents Policy Manual §7.06 http://www2.state.ia.us/regents/Policies/Chapter%207/chapter7.06.htm
OMB Circular A-110 (procurement standards relating to federally sponsored programs).
3. Contracting process
a. Signatory authority
The Board of Regents has delegated to the President of the University the authority to sign contracts and agreements binding the institution. This contracting authority has been delegated on a limited basis to other University senior officials as described in Operations Manual §V-6.1(c). Only those persons to whom this authority has been delegated may sign contracts on behalf of the University.
The responsibilities of persons with signatory authority are set forth in the University’s Policy on Signature Assignment.
b. Contract review
To ensure that any contracts proposed to the University are appropriately reviewed for acceptable business terms, the University requires that any such proposed contracts be initially routed to staff trained to perform this function in the Purchasing Department, Division of Sponsored Programs, or Clinical Trials Office, as relevant to the subject matter of the contract. Review of such contracts for the legal effect of proposed terms and conditions is to be provided by the Office of General Counsel.
c. Adherence to terms and conditions of contracts
University employees are expected to be aware of and comply with any grant or contractual obligations accepted by the University that are relevant to their work. For example, if the University accepts the contractual obligation to maintain the confidentiality of another party’s proprietary information, University employees who need access to that information for their jobs are expected to maintain its confidentiality.
4. Account management (recording, allocating, charging costs)
As a public higher education institution, the University has a fiduciary responsibility to the State of Iowa to ensure that all financial activities comply with state law and Regents and University policies. This assurance is not possible unless there is a coordinated effort among the budget officers, their departments and colleges, and the University's central administrative offices to properly administer these accounts.
5. Restriction on competition with private enterprise
Iowa law and Regents and University policy prohibit University activities that compete with private enterprise. Certain University activities (those that contribute to the education, research, extension, or service missions of the institution) are allowed by law. Proposed University activities involving the sale of goods, provision of services, or use of facilities are subject to review for compliance with this restriction.
For more information, see the University’s Policy on Competition with Private Enterprise.
Regents Policy Manual §7.06(C) http://www2.state.ia.us/regents/Policies/Chapter%207/chapter7.06.htm
6. Cash Handling
The establishment of strong internal controls for cash collections is necessary to prevent mishandling of funds and to safeguard against loss. Strong internal controls are also designed to protect employees from inappropriate charges of mishandling funds by defining employee responsibilities in the cash handling process. Cash is considered to be any type of payment for goods or services, including coin, currency, checks, money orders, credit cards, and electronic funds transfers. The University cash handling policy requires that each area receiving cash be approved by the University Business Office and be certified as a cash collection point.
For more information, see the University’s cash handling policy and procedures at
7. Grant Accounting
The University is committed to exercising fiscal management practices for its externally sponsored programs that fully comply with applicable law and the terms and conditions imposed by the receipt of grant or contract funds. This responsibility is carried out by the University’s Grant Accounting Office.
With special exceptions, grant or contract funds are not to be used to augment the full-time salary of University employees. See the University’s Policy on Supplemental Activities and Extra Compensation.
8. Reporting suspected violations
The University encourages its employees to raise concerns about violations of law or University policy relating to our business and fiduciary obligations, and has provided a Financial Misconduct Reporting System for this purpose. This reporting system may be accessed toll-free at 1-866-384-4277 or via the University of Iowa page on EthicsPoint.
In addition, the following University resources are available to all members of the University community for help with concerns in their respective areas:
Central Human Resources: 335-355
Controllers Office: 335-2791
Discrimination (Office of Equal Opportunity & Diversity): 335-0705
Employee Assistance Program:
Faculty & Staff Services: 335-2085
Faculty Senate: 335-0617
General Counsel: 335-2841
Health Protection Office: 335-8501
Hospital Emergency Room (UIHC): 356-2233
Privacy Officer – UIHC: 384-8282
Privacy Officer – University of Iowa--335-0292
UIHC 24-Hour Compliance Helpline--384-8190
Information Technology Services (ITS): 384-0800
Research Integrity Office: 335-2742
Conflict of Interest in Research Office: 335-2106
Sexual Harassment (Office of Equal Opportunity & Diversity): 335-0705
Staff Council: 335-3600
Student Services: 335-3557
Women’s Resource & Action Center (WRAC): 335-1486
Rape Victim Advocacy (RVAP): 335-6001
Rape Crisis Line: 335-6000
Domestic Violence Intervention Program (DVIP): 351-1043
Crisis Center: 351-0140