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Disclaimer: Please note the codes in our collection might not necessarily be the most recent versions. Please contact the individual organizations or their websites to verify if a more recent or updated code of ethics is available. CSEP does not hold copyright on any of the codes of ethics in our collection. Any permission to use the codes must be sought from the individual organizations directly.
500.25 Scientific Integrity
OPR: Office of Human Resources
Instruction: New SM chapter issued to establish the USGS policy for Scientific Integrity.
1. Purpose. This chapter establishes USGS policy for ensuring scientific integrity in the conduct of scientific activities and procedures for reporting, investigating, and adjudicating allegations of scientific misconduct by USGS employees and volunteers. Volunteers include all scientists working under Scientist Emeritus agreements.
2. Scope. This chapter applies to all USGS employees and volunteers.
3. Authority. Authority for this policy is the Federal Policy on Research Misconduct, Office of Science and Technology Policy, Executive Office of the President. References include:
A. Federal Policy on Research Misconduct, 65 Federal Register (FR) 76260-76264, December 6, 2000, (http://www.ostp.gov/cs/federal_policy_on_research_misconduct).
B. Standards of Ethical Conduct for Employees of the Executive Branch, 5 Code of Federal Regulations (C.F.R.) 2635, (http://www.usoge.gov/pages/laws_regs_fedreg_stats/oge_regs/5cfr2635.html).
C. Department of Interior (DOI) Manual chapter on Discipline and Adverse Actions, 370 DM 752, (http://elips.doi.gov/app_DM/act_getfiles.cfm?relnum=3705).
A. General. The USGS is dedicated to preserving the integrity of scientific activities conducted by its employees and volunteers. The USGS will ensure that all employees and volunteers understand their obligation to abide by this policy, including the USGS Code of Scientific Conduct (section 7), and the Federal Policy on Research Misconduct. The USGS will take appropriate action to protect the public from the effects of inaccurate or misleading information produced through scientific activities, and for violations of this Survey Manual chapter or the Federal Policy on Research Misconduct.
B. Privacy and Confidentiality. The investigation of an allegation of scientific misconduct will be handled in a manner that protects, as much as possible, the rights, privacy, and professional credentials of any USGS employee or volunteer who makes an allegation of scientific misconduct or who is the subject of such allegation. Investigations will be conducted in a fair and timely manner and in accordance with the Federal Policy on Research Misconduct. The Federal Policy on Research Misconduct states that to the extent possible, consistent with a fair and thorough investigation and as allowed by law, knowledge about identity of subjects and informants is limited to those who need to know. Records maintained by the agency during the course of responding to an allegation of research misconduct are exempt from disclosure under the Freedom of Information Act to the extent permitted by law and regulation.
C. Protection from reprisal for reporting scientific misconduct. The USGS is committed to ensuring that employees and volunteers who have a reasonable belief that a violation of the USGS Code of Scientific Conduct and/or the Federal Policy on Research Misconduct has occurred and who report such violation in accordance with this Survey Manual chapter will not be subject to reprisal.
D. Potential disciplinary action against USGS employees. If scientific misconduct is found to have been committed by a USGS employee, appropriate disciplinary action will be taken against the employee, up to and including removal of the employee from the Federal service. Disciplinary actions against USGS employees will be in accordance with Departmental Manual chapter 370 DM 752.
E. Potential administrative action against USGS volunteers. If scientific misconduct is found to have been committed by a USGS volunteer, appropriate action will be taken against the volunteer, up to and including termination of the volunteer agreement.
Fabrication is making up data or results and recording or reporting them. (Federal Policy on Research Misconduct)
Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record. (Federal Policy on Research Misconduct)
Plagiarism is the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit. (Federal Policy on Research Misconduct)
Research record. The record of data or results that embody the facts resulting from scientific inquiry, and includes, but is not limited to, research proposals, laboratory records, both physical and electronic, progress reports, abstracts, theses, oral presentations, internal reports, and journal articles. (Federal Policy on Research Misconduct)
Scientific activities. Activities involving inventorying, monitoring, experimentation, study, research, modeling, and scientific assessment. Scientific activities are conducted in a manner specified by standard protocols and procedures and include any of the physical, biological, or social sciences as well as engineering and mathematics that employ the scientific method. Inspections for regulatory compliance and resulting records are not included because they are covered by separate requirements.
Scientific assessment. Evaluation of a body of scientific or technical knowledge which typically synthesizes multiple factual inputs, data, models, assumptions, and/or implies best professional judgment to bridge uncertainties in the available information.
Scientific method. A method of research in which a problem is identified, relevant data are gathered, a hypothesis is formulated from these data, and the hypothesis is empirically tested.
Scientific misconduct. Fabrication, falsification, or plagiarism in proposing, performing or reviewing scientific activities and their products.
Scientific product. The results of scientific activities including the synthesis, compilation, or translation of scientific information into formats used in the Department’s decision making process.
A. All USGS employees and volunteers must comply with this chapter and the Federal Policy on Research Misconduct.
B. Each Cost Center Chief must ensure that all:
(1) USGS employees and volunteers are provided copies of USGS and Federal policies concerning scientific misconduct; and
(2) Employees and volunteers who are covered by these policies comply with USGS and Federal requirements to maintain scientific integrity and do not engage in fabrication, falsification, plagiarism in proposing, performing, or reviewing scientific activities and their products.
C. Any person with knowledge that an act of scientific misconduct may be planned, is imminent, or has occurred must report it to their supervisor or other appropriate manager or office, such as the Cost Center Chief, servicing human resources office, the USGS Ethics Office, or the DOI Office of Inspector General. In accordance with paragraph 8A(1) of this Chapter, allegations of scientific misconduct against USGS employees and volunteers must be submitted in writing to the servicing human resources office within 60 days of discovering the alleged misconduct.
7. USGS Code of Scientific Conduct
The USGS employees and volunteers who engage in scientific activities will abide by the Federal Policy on Research Misconduct, 65 Federal Register (FR) 76260-76264, December 6, 2000, (http://www.ostp.gov/cs/federal_policy_on_research_misconduct) and the following Code of Scientific Conduct:
A. I will act in the interest of the advancement of science and contribute the best, highest quality scientific information for the U.S. Geological Survey and the Department of the Interior.
B. I will conduct, process data from, and communicate the results of scientific activities honestly, objectively, thoroughly, and expeditiously.
C. I will be responsible for the resources entrusted to me, including equipment, funds, my time, and my employees’ time. I will promptly and accurately collect, use, and report all financial resources under my control; and promptly, thoroughly, and accurately report all scientific work.
D. I will fully disclose all research methods used, available data, final reports, and publications consistent with applicable laws and policy.
E. I will respect, to the fullest extent permitted by law, confidential and proprietary information provided by communities, Indian tribes, and individuals whose interests and resources are studied or affected by scientific activities or the resulting information.
F. I will maintain scientific integrity and will not engage in fabrication, falsification, or plagiarism in proposing, performing or reviewing scientific activities and their products.
G. I will welcome constructive criticism of my scientific activities, will welcome and participate in appropriate peer reviews, and will critique others’ work respectfully and objectively. I will substantiate comments that I make with the same care with which I report my own work.
H. I will be diligent in creating, using, preserving, documenting, and maintaining collections and data.
I. I will adhere to established quality assurance and quality control programs.
J. I will follow the Department’s records retention policies and comply with Federal law and agreements related to use, security, and release of confidential and proprietary data.
K. I will adhere to appropriate standards for reporting the results of scientific activities and will respect the intellectual property rights of others.
L. I will, to the extent possible and practical, differentiate among facts, opinions, hypotheses, and professional judgment in reporting the results of scientific activities to others, including scientists, decision makers, and the public.
M. I will be responsible for the quality of any data I collect or any interpretations I make, and for the integrity of conclusions I draw in the course of my scientific activities.
N. I will place quality and objectivity of scientific activities and reporting of their results ahead of personal gain or allegiance to individuals or organizations.
8. Procedures. A flow chart of the process to be followed in cases of alleged scientific misconduct is contained in Figure 1, Flow Chart of Actions to be Taken in Cases of Alleged Scientific Misconduct.
A. Allegations of scientific misconduct.
(1) Allegations of scientific misconduct against USGS employees and volunteers must be submitted in writing to the servicing human resources office within 60 days of discovering the alleged misconduct. In cases of fraud, waste, and abuse that are referred to the DOI Office of the Inspector General, the ability to report misconduct is not time limited. Allegations shall contain the following information:
(a) The name, office location, and signature of the person or persons reporting the alleged scientific misconduct.
(b) The name and office location of the person or persons alleged to have committed the alleged scientific misconduct.
(c) A description of the allegation, with as much detail as possible about the nature of the scientific conduct and the circumstances.
(d) Date(s) the alleged scientific misconduct occurred or continues to occur.
(e) Documents and/or other relevant items (such as data, materials, etc.) pertaining to the alleged scientific misconduct.
B. Inquiry of allegation of scientific misconduct.
(1) Upon receipt of an allegation of scientific misconduct, the servicing human resources office will contact the immediate supervisor of the subject of the inquiry (henceforth referred to as the subject) to inform them that an allegation of scientific misconduct has been filed.
(2) The servicing human resources office will provide assistance to the supervisor in conducting an inquiry to determine if the allegation is covered under the provisions of this chapter and will provide consistency, oversight, and guidance throughout the entire process. The supervisor will ensure that all original research records and materials relevant to the allegation are immediately secured. Once the evidence is secure, the subject will be notified in writing (Appendix A, Notification of Preliminary Investigation) that an allegation of scientific misconduct has been filed against them. A supervisor should never act alone in determining the merit of an allegation, but must work with the servicing human resources office.
(3) If after review of the information gathered during the inquiry the supervisor determines that an investigation by the Scientific Misconduct Review Panel (SMRP) (Appendix B, Scientific Misconduct Review Panel) is not required, no further action will be taken against the subject. The supervisor will issue a memorandum to the subject explaining that no further action will be taken concerning this incident, and that the case will be closed (Appendix C, Sample Closure Memorandum). If the subject is a USGS employee, he/she may provide a copy of this memorandum to his/her servicing human resources office for placement on the left hand side (temporary side) of the Official Personnel Folder, where it will be retained for one year, in accordance with the USGS General Records Disposition Schedule 432-1-SI.
(4) If it is determined that an investigation is required, the supervisor will refer the matter to the Chairperson of the SMRP and will inform the subject that the allegation of scientific misconduct will be investigated by the SMRP. At this time, the appropriate Cost Center Chief will be verbally informed of the investigation.
(5) Allegations of scientific misconduct that involve alleged fraud, waste and abuse, or criminal law violations will be referred to the DOI Office of the Inspector General (OIG).
(6) Allegations of administrative, non-scientific misconduct against a USGS employee or volunteer will be handled through normal administrative processes, in accordance with DOI/USGS regulations and union contracts.
C. Investigation by Scientific Misconduct Review Panel (SMRP)
(1) The SMRP shall consist of a Chairperson, four additional scientists, and an alternate scientist. The alternate will serve on the panel when it is necessary for one of the panel members to recuse themselves because of a conflict of interest or if a panel member is prevented from participation for some other reason. The Director of the USGS, in consultation with the Discipline Chief Scientists, shall appoint the panel members. Panel members will serve a 4-year term and may serve for no more than two consecutive terms. To ensure panel continuity, half of the originally selected panel members will serve for 2-year terms and half of the originally selected panel members will serve for 4-year terms. Ad hoc panel members may serve as panel members in order to provide necessary technical assistance. They may be chosen from a specific discipline or a specific area of expertise that is not represented on the permanent panel. The Chairperson, with the concurrence of the Director, will select these panel members as needed. The Director may replace any panel member at any time.
(2) The subject of the investigation will be notified by the Chairperson of the Panel that the SMRP will be convened to conduct an investigation of the allegation of scientific misconduct. The subject will be advised of the investigation and his/her rights and responsibilities during this process. Subjects will be asked to sign the Employee/Volunteer Information and Acknowledgement Form (Employee form at Appendix D, Volunteer form at Appendix E) acknowledging he/she has been notified of the investigation, his/her rights and responsibilities in complying with the investigation, the consequences of not fully complying to the best of his/her abilities, and the opportunity to respond to the allegation and present testimony and evidence to the panel orally and/or in writing. The Chairperson of the Panel shall retain the original of the form and provide a copy of the signed document to the subject of the allegation.
(3) The Panel will conduct an investigation utilizing one or both of the following methods: (a) securing and reviewing documentary evidence, including all original experimental records, protocols, and data; (b) interviewing relevant persons, whether in person or by telephone, and, as necessary, securing written statements from the interested parties. The Panel will provide the subject of the investigation with the opportunity to respond to the allegation and present evidence and testimony to the SMRP.
(4) Three criteria are necessary to establish research misconduct (Federal Policy on Research Misconduct): (1) There is a significant departure from accepted practices of the relevant research community; (2) the misconduct is committed intentionally or knowingly or recklessly; and (3) the allegation is proven by a preponderance of evidence. The Panel will arrive at a consensus decision, if possible. Consensus decision means that all panel members, including the Chairperson, agree with a decision. This is distinct from a majority-rule decision. In the consensus-based process, panel members work together to develop a finding with which all of the members of the panel can agree. The Chairperson will determine if consensus has been reached by asking all panel members if they agree with the finding. If consensus is reached, then the Panel shall write a report of their findings that contains a summary of the findings, the basis for determining whether or not scientific misconduct occurred, and an assessment of the seriousness and extent of any misconduct found that is in violation of the USGS Code of Scientific Conduct.
(5) The Panel will take the time necessary to address all of the relevant issues associated with the allegation in order to reach a consensus finding. If, after all efforts are exhausted, the Panel is still unable to reach consensus about whether or not misconduct has occurred, then a majority decision will be made. Panel members will write majority and minority reports to send to the subject’s immediate supervisor and the servicing personnel office.
(6) Within 30 calendar days of the completion of the report, the Chairperson of the Panel shall forward the report to the servicing human resources office and the subject’s immediate supervisor for appropriate action.
D. Administrative Action. After receiving the report, the servicing human resources office and the immediate supervisor will determine possible corrective action and, if necessary, appropriate disciplinary action/adverse action for the subject in accordance with DOI/USGS policies and /or union contracts, as applicable. Within 30 days of receipt of the report, the servicing human resources office specialist and the immediate supervisor will meet with the subject to discuss any pending disciplinary/adverse action. If disciplinary/adverse action is proposed, the subject will be provided with a written notice containing the following information: the specific nature of the offense, the type of disciplinary/adverse action being proposed, a right to answer (orally, in writing, or both), the material relied upon regarding the action, and the right to representation. Once a decision is made, a written decision and appropriate appeal rights will be provided to the subject.
If, based on the report issued by the SMRP, no administrative action will be initiated, the subject’s supervisor will notify the subject and Cost Center Chief in writing of the finding. A copy of this memo will be included in the record.
E. Appeal Rights for USGS Employees. For disciplinary actions up to and including a 14-day suspension, subjects have the right to appeal through the Administrative Grievance procedure or a Negotiated Grievance Procedure (NGP) if the subject is covered by a collective bargaining agreement. For suspensions of more than 14-days or removal from the Federal service, subjects have the right to appeal to the Merit Systems Protection Board or through an applicable NGP.
F. Reconsideration Rights for Volunteers. Volunteers have the right to appeal findings of scientific misconduct and associated actions to the Director of the USGS.
G. Notification of person filing the allegation: At the conclusion of the process, the person who filed the allegation will be notified by the servicing human resources office that management has taken appropriate action and that the matter has been resolved.
H. Records. Servicing human resources offices will submit a report each calendar year to the Bureau Human Resources Officer. The report will list (1) the number of allegations of scientific misconduct filed against employees and against volunteers, (2) whether or not scientific misconduct was found and (3) the disciplinary or other action taken, if any. These reports will be retained in accordance with Section 407 of the U.S. Geological Survey General Records Disposition Schedule 432-1-S1 and the Privacy Act.
Data that serve to document any allegation or finding of scientific misconduct will be retained by the servicing human resource offices in accordance with Section 407 of the U.S. Geological Survey General Records Disposition Schedule 432-1-S1 and the Privacy Act.
Mark D. Myers Director, U.S. Geological Survey
Disclaimer: Please note the codes in our collection might not necessarily be the most recent versions. Please contact the individual organizations or their websites to verify if a more recent or updated code of ethics is available. CSEP does not hold copyright on any of the codes of ethics in our collection. Any permission to use the codes must be sought from the individual organizations directly.
The Schwan Food Company Business Ethics Code of Conduct
The Schwan Food Company recognizes that employees
have an inherent understanding of ethical business conduct.
Our mission is: “Delight consumers with an unmatched
food experience that delivers superior value.” To achieve this
mission, we must be diligent in ensuring that our reputation
is maintained in every country, community, and location
where we do business. Our business ethics program is
the guiding principle of who we are and how we conduct
The business ethics program consists of our Code of
Conduct, ongoing communication and training, and
communication channels in which individuals can ask
questions or communicate concerns. The goal of the
business ethics program is to prevent, identify, and
correct issues as we continue to serve our valued customers.
Our Business Ethics Code of Conduct guides all of us,
from board of directors to new employees, to achieve
the highest level of ethical business conduct. Each of us
is responsible for becoming familiar with the Code and
applying its principles.
We have a rich heritage, which is reflected in our core
values and in our Code of Conduct. We are committed
to ensuring that our actions reflect our words. Remember
that our reputation and our future depend on the manner
in which we conduct ourselves and the decisions we make
Allan L. Schuman Greg Flack
Chairman of the Board CEO, President and COO
Allan L. Schuman
Chairman of the Board
CEO, President and COO
BUSINESS ETHICS LINE 1.800.818.9065
Table of Contents
The Schwan Business Ethics Program Overview ..................................2
Worldwide Applicability. .........................................................................2
Our Core Values and Code of Conduct .................................................3
Knowing and Complying with the Code and Law ................................3
Asking Questions and Communicating Concerns ................................4
Follow-up and Retaliation .......................................................................6
We are Responsible for Telling the Truth ...............................................6
Mutual Respect .................................................................................................7
Dignity in the Workplace ........................................................................7
Health and Safety ....................................................................................8
Business Practices .............................................................................................9
Competition / Antitrust ..........................................................................9
Insider Trading .......................................................................................10
Conflicts of Interest / Entertainment & Gifts .....................................11
Vendor Relationships .............................................................................13
Use of Company Resources ...................................................................14
Accuracy & Retention of Business Records .........................................15
Confidential and Proprietary Information ............................................17
Media and Public Discussion ................................................................18
Civic and Political Activity ....................................................................18
Regulatory & Legal Inquiries................................................................19
THE SCHWAN BUSINESS ETHICS PROGRAM OVERVIEW
The Schwan Business Ethics Code of Conduct is a guide to the ethical and legal
responsibilities governing each of us. It is not a complete rule book that addresses
every ethical issue, nor a summary of all laws and policies. Rather, the Code gives us
guidance and directs us to resources to help make the correct decisions. Throughout
the Code of Conduct, we speak of company rules and policies. In these cases please
refer to the employee handbook, your supervisor, or Human Resources for the
specific policy guidelines.
We acknowledge and appreciate the wide variety of cultural and political differences
of the countries in which we operate. While we recognize local laws and customs
may dictate the necessity for this Code to be flexible, we do expect all employees to
adhere to the philosophies and underlying principles of the document.
The Ethics and Law departments are corporate support functions. As such, guidance
should be sought from these resources when necessary regardless of the country in
which your respective business operates.
*Note: All references to “Schwan” or “the company” throughout this document includes the
subsidiary companies of Th e Schwan Food Company.
OUR CORE VALUES & CODE OF CONDUCT
Schwan values growth, helping one another, enthusiasm, hard work and integrity.
These values are the foundation of the Business Ethics Code of Conduct. The
Code is the cornerstone of the Schwan business ethics program and applies to all
employees, contractors, officers, and members of the board of directors.
In complying with the Code of Conduct, the following basic questions should guide
• Do you believe that what you are doing or are being asked to do may be illegal
• Could someone’s health or safety be endangered by the action?
• Would you be unwilling or embarrassed to tell your family, friends, or co-workers?
• How would you feel if this was reported in a newspaper?
• Is it the right thing to do?
WE ARE RESPONSIBLE FOR KNOWING AND
COMPLYING WITH THE CODE AND THE LAW
It is the duty of all of us to know, understand, and comply with the Code of Conduct
and applicable laws. It is part of our jobs, of our responsibility, of who we are and how
we conduct business.
WE ARE RESPONSIBLE FOR ASKING QUESTIONS AND COMMUNICATING CONCERNS
If you have a question or a concern about a point of ethical conduct, there are
a number of channels available for assistance. As employees, we each have a
responsibility to communicate any circumstances or actions that violate or appear to
violate the principles of the Code of Conduct. Your resources for seeking assistance or
communicating concerns include:
• Your supervisor or another member of management
• A Human Resources Representative
• The Ethics Department
The Schwan Food Company
115 West College Drive
Marshall, MN 56258
• The Business Ethics Line
The company provides a business ethics telephone line within the United States
and Canada. The business ethics line is managed and staffed by an independent
third-party firm that is experienced in handling sensitive matters. The line
provides the means to ask questions, receive guidance, or communicate concerns.
Company operations outside the United States and Canada may be subject to
local laws or regulations that govern the use of such an ethics line. An ethics line
may not be available for use in these other countries. For clarification regarding
the rules that apply to the country in which you work, you should contact your
supervisor, a member of management, or a Human Resources representative.
Nonetheless, even if an ethics line is not available within your country of
employment, the traditional methods of presenting questions or issues to a
supervisor, another member of management, or a Human Resources representative
are available to you.
Employees within the United States and Canada can contact the business ethics
line 24 hours a day, 7 days a week at 1-800-818-9065 and have the option to
Within the U.S.: 1-800-818-9065 (You may remain anonymous.)
Within Canada: 1-800-818-9065 (You may remain anonymous.)
• The Law Department
The Schwan Food Company
115 West College Drive
Marshall, MN 56258
The following chart should help you see the process for seeking assistance,
asking a question, or raising a concern:
an ethical issue.
Contact direct Call the respective
supervisor, a member business ethics line
of managment, or if available in
human resources. his/her country.
Receive guidance. --------- The call
Make an is sent to the
informed decision. Ethics Department.
action is taken.
FOLLOW UP AND RETALIATION
The business ethics program is designed to ensure that anyone acting in good faith
has the means to communicate questions, concerns, or apparent violations of the
Code of Conduct without fear of retaliation. The laws that govern the use of business
ethics lines diff er by country. In some countries, business ethics line callers may be
able to remain anonymous and no attempt will be made to identify them. However,
callers should know that it is often more difficult to appropriately investigate issues
raised anonymously. Callers within the United States and Canada do have the option
Retaliation in any form against an individual who in good faith reports a known or
suspected violation of the Code of Conduct, a law, or other policy is itself a violation
of company policy and the Code of Conduct. Suspected acts of retaliation should be
reported immediately to the Ethics Department.
WE ARE RESPONIBLE FOR TELLING THE TRUTH
Investigations of actual or potential violations of the Code of Conduct or other
company policies or laws may be conducted. Discussions are a fundamental part of
the process whether they relate to a question, concern, or investigation. If
you are interviewed or asked to provide information regarding an actual or potential
violation, it is important, necessary, and required that you cooperate fully and
DIGNITY IN THE WORKPLACE
No matter what Schwan business you work for, or what part of the world you work
in, everyone deserves to be treated fairly and with dignity. We are committed to a
policy of equal opportunity for all qualified applicants and employees without regard
to race, color, gender, religion, age, national origin, ancestry, disability, military status,
or other legally protected status.
We are committed to providing a workplace that is free from harassment,
intimidation, and abuse.
Example Application – Question & Answer
Q: The quality assurance manager asks one of his subordinates out on a
date. The subordinate is not interested in dating him, but is scared to say no
because her manager has stated that it would be beneficial for her career for
her to go out with him.
A: The subordinate should say no to her manager and contact another
member of management, a Human Resources representative, or the business
ethics line to report the issue. Please refer to company policy in regard to
acceptable relationships in the work place.
Q: A facility supervisor is reviewing the applications he received for
an open material handler position. There are five male applicants and one
female. When deciding who to call back for an interview, he decides not to
call the female back because the last female employee he hired was not a
very hard worker.
A: This decision on the part of the facility supervisor is inappropriate. All
applicants must have equal opportunity for employment. No decisions or
assumptions should be made based on an applicant’s race, gender, religion,
age, national origin, ancestry, disability, military status, or other legally
HEALTH & SAFETY
Schwan is committed to providing a safe work environment. We all have a
responsibility to abide by all applicable laws, rules, practices, and precautions to
protect ourselves, coworkers, and our customers. This includes reporting to work
free from the influence of any illegal or controlled substances that could prevent one
from conducting work activities safely. We all have a responsibility to immediately
communicate accidents and unsafe practices or conditions to appropriate personnel.
Example Application – Question & Answer
Q: The truck that a route sales representative (RSR) is scheduled to use
is in need of some vital repairs. Prior to informing his manager about the
necessary repairs, the RSR asked a coworker if there are any spare trucks
available for that day. He is told there are not, so he decides to use the truck
anyway so that he does not have to make the day up on Saturday.
A: The decision to use the impaired truck is wrong. Not only does it put
the RSR in danger, it also puts the general public in danger and violates
Department of Transportation (DOT) regulations. Employees should
always report mechanical issues with company vehicles or equipment to
Q: You become aware that the wrong ingredients were used to make
sundae cones. You are not sure if you should tell your supervisor due to the
amount of overtime it would take to start from scratch and the financial
hardship it would cause the company.
A: Inform your supervisor immediately. The safety of our products and
our customers is our first priority.
The countries in which Schwan operates now or in the future have fair competition
or antitrust laws that safeguard the rights of consumers and prohibit restraint of
trade, unfair practices, or abuse of economic power. The company is committed to
conducting business in a manner that promotes fair competition and free enterprise
consistent with these principles. In general, agreements to fix or control prices,
agreements to allocate markets or customers, or agreements in which a seller refuses
to sell one product unless the buyer agrees to purchase another product are contrary
to these principles and our Code of Conduct. If you have questions about how
the antitrust or similar laws apply to a particular situation, please seek appropriate
guidance from applicable company policy, a member of management, the Law
Department, or the Ethics Department.
Example Application – Question & Answer
Q: A customer sales representative received a phone call from a
competitor’s sales representative. During the conversation, the competitor
stated how many hours he had worked lately and that it would be nice if
he didn’t have to service quite as many stores. He suggested that he and the
company’s representative should divide the city in half and each service one
A: The company’s customer sales representative declined the offer and
reminded the competitor that it is illegal to enter into any such agreement.
The Schwan Food Company and its subsidiary companies are privately-held
companies. However, there are various securities laws to which we are bound and
committed. Employees may come into possession of confidential and highly sensitive
information relating to public companies. Those who have non-public information
relating to a public company, may not use that information for their own benefit or
the benefi t of others and may not pass that information on to others or encourage
others to make transactions involving the securities of that public company.
It is Schwan policy that employees who have non-public information may not buy or
sell the securities of that public company until such time after public disclosure of the
information as required under the applicable laws of the country concerned. If you
have questions regarding how securities or similar laws apply to a particular situation,
please seek appropriate guidance from applicable company policy, a member of
management, the Law Department, or the Ethics Department.
Example Application – Question & Answer
Q: An area sales manager considered buying stock in a regional grocery
store which is one of her customers. She decided that it would be a good
idea to discuss the situation with her manager first to ensure that it would
not be a violation of the Code of Conduct.
A: Since the area sales manager has a business relationship with the
grocery store, she may be inclined to make questionable decisions on behalf
of Schwan to ensure that her personal stock is more profitable. The area sales
manager was right to seek guidance.
Example Application – Question & Answer
Q: An administrative assistant heard a rumor that Schwan would be
acquiring a small publicly traded frozen-food manufacturer. She thought
it may be a good financial decision to purchase some of the publicly traded
company’s stock before the transaction was finalized and made public. She
decided to contact her manager prior to making a final decision.
A: Individuals who obtain non-public information may not purchase or
sell securities until such time after public disclosure of the information as
required under the applicable laws of the country concerned. Purchasing the
stock would have been a violation of the Code of Conduct. She was right to
CONFLICTS OF INTEREST / ENTERTAINMENT & GIFTS
A conflict of interest exists where an individual’s interests conflict with the interests
of Schwan. While conducting the company’s business we must avoid conflicts of
interest, or the appearance of a conflict of interest, as well as any relationship or
activity that might impair one’s ability to make objective and fair decisions when
performing at work. Schwan is committed to competing on the basis of the quality of
its products and services. Employees should avoid any actions that result in business
being gained in exchange for any gift, meals, or entertainment. We should also avoid
actions that create the impression that business was gained in exchange for gifts,
meals, or entertainment.
Some examples of potential conflict situations are:
• Employees or members of their immediate family affiliated with a fi rm which either
provides goods or services to a Schwan business unit or is a competitor of Schwan;
• Employees or members of their immediate family acting as a contractor,
vendor, or consultant to Schwan;
• Holding a second job that interferes with your employment with Schwan;
• Use of Schwan’s confidential information in a way that advantages the employee or
members of their immediate family.
The giving or receiving of gifts can create a conflict of interest or can appear to be
a conflict of interest. To ensure that business-related gifts, meals, or entertainment
are not subject to abuse and do not create or appear to create a conflict of interest,
Schwan only permits gifts to be given or received if they are limited in occurrence
and reasonable in value. Gifts also must not influence or give an appearance of
influencing the recipient. Employees may accept occasional meals, refreshments,
entertainment, and similar business courtesies so long as they are not lavish or
excessive and do not create the appearance of an attempt to influence business
decisions. Under no circumstance will any employee accept or give any gift or
courtesy as a bribe. More specific guidance is available in company policy or from an
appropriate member of management.
The Foreign Corrupt Practices Act (United States) and the laws of other countries
restrict the giving or receiving of gifts, meals, and entertainment to government
officials. Schwan prohibits gifts to or from government employees unless applicable
regulations permit the giving and acceptance of the gift. We prohibit payment of
gratuities to public officials to expedite or obtain routine governmental actions, except
where such practices are lawful and customary. In such cases, payments must be
limited to customary amounts, be properly documented, and be approved in advance
by the Law Department.
Example Application – Question & Answer
Q: A route sales representative (RSR) is scheduled to service his mother
on his weekly route. Th e RSR wonders if this creates any issues in complying
with the Code of Conduct. He decides to discuss the situation with his
A: Th is does create a special situation. All customers must be treated
fairly. The relationship between the RSR and his mother may create an
appearance of preferential treatment towards her. Th e decision may be made
to give his mother’s account to another RSR. Th e RSR was right to seek
Q: A territory sales leader (TSL) is accepting bids for snow removal and
lawn maintenance for his depot. Th e TSL gives one of the depot employees
the details of the competing firms to ensure that the employee’s son will win
A: The TSL violated company policy and the principles of fair
competition in the bidding process by disclosing the bid information.
In addition, it may be inappropriate for the son of an employee to be a
contractor for the depot.
Example Application – Question & Answer
Q: While establishing an internet connection in a foreign country, a
manager was informed by an employee of the government-owned telephone
company that an additional $20 would have to be paid to ensure that the
internet connection would be established within the required deadline.
A: Any time an additional payment is required or requested by a
governmental official, contact must be made with the Law Department. The
Law Department is responsible for making the determination as to whether
the requested payment is legal, reasonable, and customary. Th e payment
must also be fully documented to ensure full disclosure.
We select our suppliers, vendors, and contractors in a non-discriminatory manner
based upon the quality, price, service, delivery, and supply of goods and services. Such
decisions must never be based on personal interest or the interests of family members.
All vendor, supplier, and business relationships with outside parties should be
formalized in written agreements in accordance with company purchasing and
contracting policies. It is generally not appropriate for an employee to also act as a
vendor to the company.
Example Application – Question & Answer
Q: A new vendor for a Schwan subsidiary learns that the category
director is a football fan. In recognition for the new account that was
established, the vendor sent the category director two tickets to the game
for the director and a guest.
A: In this case, there appears to be no business purpose to the outing. The
director should refer to company policy and/or seek appropriate guidance
regarding the appropriateness of accepting the tickets.
USE OF COMPANY RESOURCES
Schwan provides the necessary resources to its employees for the purposes of
fulfilling their responsibilities. Resources include materials, financial assets, inventory,
land, equipment, technology, information, and an employee’s time at work. The
use of Schwan Resources for personal business, individual profit, or any unlawful,
unauthorized, or unethical purpose is prohibited by company policy.
The computer systems (including e-mail and Internet access) are Schwan resources
and are provided for legitimate business activities by authorized individuals.
Employees should not have an expectation of privacy regarding the use of computer
systems, e-mail, Internet, or other Schwan programs.
Example Application – Question & Answer
Q: An Information Services Department (IS) employee receives a request
from a friend for a list of all of the company e-mail addresses. The friend
wants to use the e-mail addresses to solicit business for a new company.
A: The IS employee explained to his friend that it is against company
policy to share company e-mail addresses for non-Schwan related purposes
and declined his request.
ACCURACY & RETENTION OF BUSINESS RECORDS
It is the company’s policy to record and report its business information honestly and
accurately. Individuals involved in creating, transmitting, or entering information
into Schwan financial and operational records are responsible for doing so accurately
and with appropriate supporting documentation. No officer, employee, or agent may
make any entry that intentionally hides or disguises the true nature of a transaction.
Compliance with established company policies, our system of internal controls,
and generally accepted accounting principles is necessary at all times. Instances of
employees knowingly entering false or inaccurate information into the Schwan
accounting or other systems is prohibited and may be illegal.
Our commitment to accuracy and appropriate retention of business records includes
prohibiting unauthorized destruction of or tampering with any records, whether in
written or electronic form, when we are required to maintain the records or when we
have reason to know of threatened or pending government investigation or litigation
relating to the records. Records include such things as paper copies, electronic files,
audio/video recording, microfiche, and microfilm. If you have questions about
whether particular records should be retained, please seek appropriate guidance from
applicable company policy, a member of management, the Law Department, or the
Example Application – Question & Answer
Q: As the year is coming to a close, the manager of a bakery plant realizes
operations have already exceeded the annual business plan. Th e plant
manager asks the division chief financial officer if the remaining profit for
the year can be reported at a later date in order to have a head start on the
A: Doing so would cause false and inaccurate information to be
recorded. Th is action is inappropriate and a violation of the Code of
Conduct. All income and expenses must be recorded in the period in
which they are earned.
Example Application – Question & Answer
Q: A food service salesperson had a customer who demanded that the
salesperson alter an invoice. Th e customer wanted the invoice to show a
higher price than what was actually paid and to show delivery to a different
store. Th e customer stated that he would no longer do business with Schwan
unless the salesperson agreed to falsify the invoice.
A: Th e salesperson refused to make the changes because he knew it
would be a violation of the Code of Conduct. Losing a customer with
questionable ethics is much better than compromising the integrity of
Q: While traveling for business, two employees had dinner together. The
senior of the two employees paid for the meal and was reimbursed by the
company for the expense. The other employee took a copy of the receipt and
turned it in as well for reimbursement.
A: The action of the second employee is not only a violation of the Code
of Conduct, but it is also illegal - he stole from the company.
Q: An hourly employee is having a hard time keeping up with his
workload. He knows he has the necessary programs on his home computer
to complete his work so he decides to complete the tasks over the weekend.
A: These tasks are considered a part of his job, no matter where the
tasks are completed. Hourly employees are not allowed to complete work
functions without being compensated. The employee should speak to his
supervisor and work out an arrangement that will allow the tasks to be
completed and to be compliant with all applicable laws.
Q: A route sales representative (RSR) arrives at the depot early on a
Monday morning for a safety meeting. She does not punch in because she
doesn’t want the time spent at the meeting to be counted against her DOT
A: Company policy and DOT regulation require all time spent
performing work functions to count as hours-of-service time. The
employee must clock in to ensure this time is included in her DOT
CONFIDENTIAL & PROPRIETARY INFORMATION
We all have a responsibility to safeguard confidential business information and use
such information only for company purposes. Confidential business information
includes without limitation, the company’s inventions; trade secrets; business
plans and projections; sales, cost and profit figures, and projections; new product
or marketing plans; customer details and programs; research and development
ideas or information; manufacturing processes or methods; personnel information;
information regarding potential acquisitions, divestitures and investments; and any
other matters considered or reasonably expected to be considered confidential by the
Each of us has a responsibility to protect confidential proprietary information.
Releasing such information must be done with a valid business purpose, proper
authorization, and, as appropriate, a properly executed confidentiality agreement.
Schwan expects the same commitment to confidentiality from its consultants and
suppliers. Employees will not do business with suppliers or vendors who need access
to the company’s confidential information until an appropriate confidentiality
agreement is accepted by the suppliers or vendors. If you have questions about this,
please seek appropriate guidance from applicable company policy, a member
of management, the Law Department, or the Ethics Department.
Example Application – Question & Answer
Q: A marketing manager is preparing an ad campaign for a new type of
pizza. She is very excited about the product and the plan she has developed
to take it to market. She would like to discuss the concept with a friend
who works for an outside advertising company. She is not sure if this is a
violation of the Code of Conduct so she decides to check with her manager
A: She made the right decision to check with her manager. Sharing nonpublic
information with someone outside of the company is a violation of
the Code of Conduct.
MEDIA & PUBLIC DISCUSSION
The Public Relations & Communication Department is responsible for all contact
with the media. This includes newspapers, magazines, trade publications, radio,
television as well as any other external sources looking for information about
Schwan. Unless you are specifically authorized to represent Schwan to the media, any
request for information must be referred to the Public Relations & Communication
All of us must be careful not to disclose any confidential, personnel, or business
information through public or casual discussions, or to the media. Any stories,
articles, speeches, records of operations, pictures, or other material in which the
company name is mentioned or indicated, must be submitted through your
supervisor, for approval by the Public Relations & Communication Department prior
Schwan is committed to conduct its business in an environmentally conscientious
manner that is socially responsible, scientifically based, and economically sound. It is
Schwan policy to abide by all applicable environmental laws and regulations.
CIVIC AND POLITICAL ACTIVITY
We believe governments benefit from citizens who are politically active. For this
reason, the company encourages each of us to participate in civic and political
activities in his or her own way.
Schwan is prohibited by U.S. federal law from contributing to any campaign for
federal elected office, and to campaigns in states or other countries with similar
prohibitions. The financial and other resources of the company shall not be used for
any direct or indirect political activity, except where allowed by law.
Only employees specifically authorized by the company can lobby elected or
appointed government officials to influence proposed or existing legislation,
regulation, rule, code, or ordinance that affects Schwan business. Those employees are
responsible for knowing and strictly conforming to the legal requirements applicable
to such matters.
Participation in voluntary political action committees (PAC) which operate in
accordance with the law is permitted. Schwan corporate policy provides guidance
related to employee political activity. Consult the Government and Community
Affairs Department or the Law Department if you have any questions in this area.
Example Application – Question & Answer
Q: Th e company is sponsoring an ice cream social at one of the local
elementary schools during parent teacher conferences. One of the
employees who signed up to hand out ice cream is also running for the
school board. While he is handing out ice cream, he also distributes some
A: These actions are inappropriate because an employee is using
corporate resources to conduct a political campaign in violation of company
policy and campaign law. For additional guidance regarding civic and
political activities, contact the Government and Community Affairs
Department or the Law Department.
REGULATORY & LEGAL INQUIRIES
It is Schwan’s policy to cooperate with government authorities in their proper
performance of inquiries or investigations. It is important that such matters be
properly coordinated with Schwan. Any inquiry from government officials or entities
may include requests for information, notice of an investigation, or the service of a
Any inquiry from a government official or entity should be referred to the Law
Department, unless you have been specifically authorized to respond to such
inquiries. In that case, you are required to provide accurate information and fully
inform the Law Department.
BUSINESS ETHICS LINE: 800-818-9065
COMPANY E-MAIL: firstname.lastname@example.org
©2012 The Schwan Food Company. All Rights Reserved.
Disclaimer: Please note the codes in our collection might not necessarily be the most recent versions. Please contact the individual organizations or their websites to verify if a more recent or updated code of ethics is available. CSEP does not hold copyright on any of the codes of ethics in our collection. Any permission to use the codes must be sought from the individual organizations directly.
APSC Code of Conduct
APS employees are required, under the Code of Conduct, to behave at all times in a way which upholds the APS Values
The Code of Conduct requires that an employee must:
- behave honestly and with integrity in the course of APS employment;
- act with care and diligence in the course of APS employment;
- when acting in the course of APS employment, treat everyone with respect and courtesy, and without harassment;
- when acting in the course of APS employment, comply with all applicable Australian laws;
- comply with any lawful and reasonable direction given by someone in the employee's Agency who has authority to give the direction;
- maintain appropriate confidentiality about dealings that the employee has with any Minister or Minister's member of staff;
- disclose, and take reasonable steps to avoid, any conflict of interest (real or apparent) in connection with APS employment;
- use Commonwealth resources in a proper manner;
- not provide false or misleading information in response to a request for information that is made for official purposes in connection with the employee's APS employment;
- not make improper use of:
- inside information, or
- the employee's duties, status, power or authority, in order to gain, or seek to gain, a benefit or advantage for the employee or for any other person;
- at all times behave in a way that upholds the APS Values and the integrity and good reputation of the APS;
- while on duty overseas, at all times behave in a way that upholds the good reputation of Australia; and comply with any other conduct requirement that is prescribed by the regulations (regulations available on the ComLaw website)
The University of Connecticut Code of Conduct
Letter from the President
The University of Connecticut is committed to
assuring the highest standard of integrity in all
aspects of University life and in all University
and University-sponsored activities. While this
goal is simply stated, its attainment requires
concerted effort on the part of all members of
the University community, particularly faculty,
administrators and staff. Federal, state and local
regulations which govern our activities are increasingly complex, and as the
University’s activities expand in size, scope and prominence, it is important
that all of us understand relevant policies and know what is required in
terms of compliance and reporting.
The University of Connecticut Board of Trustees is the body that is
ultimately responsible for ensuring full compliance. At the Board’s
direction, the University has established a Compliance Program to help in
our efforts to adhere to all federal, state and local regulatory requirements.
A key ingredient of an effective Compliance Program is the establishment of
a Code of Conduct. This Code of Conduct was developed with input from
faculty, administrators and staff.
This Code serves to guide the conduct of University activities in support of
the University’s mission and is designed to serve three key purposes:
1. To set the basic standards of workplace behavior that the University
expects of all faculty, administrators and staff.
2. To state publicly the University’s long-term commitment to the
highest standards of integrity in education, research, health care,
public engagement and service.
3. To assure that faculty, administrators and staff understand their
shared responsibility for keeping the University in full compliance
with all applicable laws, regulations and policies.
Please read the Code carefully, and take all steps necessary to apply its
standards. The University’s Office of Audit, Compliance and Ethics is
responsible for monitoring compliance and serving as a resource for
questions and guidance on the Code, and on the University policies and
procedures that spell out compliance requirements in greater detail.
A key element in assuring University-wide compliance is a system for
reporting potential violations. In an institution this large and active, there
may be areas of confusion; regrettably, there may also be instances in which
individual behavior does not meet appropriate ethical expectations. Any
University employee who observes a possible violation of law, regulation,
policy or approved procedure has an obligation to report it. While a key
element is reporting inappropriate activity, I want to emphasize that the
most important element of any compliance or ethics program is working
cooperatively to assure a positive climate of openness and integrity. Great
universities function as true communities in which faculty, administrators,
staff and students collaborate to achieve common goals. That holds true
for instruction, research, public engagement, service and, at the most
fundamental level, ethical compliance.
I want to thank you for understanding and adhering to these standards, and
for your commitment to the highest level of ethical conduct in fulfillment
of our institutional responsibilities.
The University of Connecticut Ethics Statement
The standards contained in this Code of Conduct reflect the University of Connecticut’s core values as they have been articulated over time by generations of faculty, staff, administrators, students and the State of Connecticut. These values are essential and enduring tenets of our organization. A statement of these values, while reiterating concepts already well understood, is helpful in outlining the context in which our Code will operate. Please be advised that violation of the standards in this Code of Conduct may result in appropriate disciplinary measures up to and including dismissal.
Members of the University community value truth, the pursuit of truth, intellectual curiosity and academic freedom. Our faculty and students seek to create new knowledge and are committed to sharing ideas, research findings and the products of intellectual and creative pursuits with the broader community.
Members of the University community are truthful and sincere in their words and actions and do not intentionally mislead others or provide inaccurate information.
Institutional and individual behaviors at the University reflect fundamental moral and ethical values. Our actions are beyond reproach and avoid both the fact and the appearance of impropriety.
The University honors and respects individuality and demonstrates tolerance for the personal beliefs and cultural differences of all individuals. As members of an academic community, we seek to foster a spirit of civility and collegiality through open and honest communication. We strive to protect the health, safety and wellbeing of all persons. We protect the private and confidential information that is provided by our patients and research participants, faculty, administrators, staff, students, volunteers and others. We value an environment that is free from harassment, intimidation, bullying, incivility, disrespect and violence.
The University and its members expect that the professional standards and requirements that are applicable to the academic, research, clinical, engagement, administrative and other professions comprising our community will be followed. We are responsible and accountable for our actions and are expected to make reasonable efforts to comply with all applicable federal, state and local government laws and regulations. As individuals and as an institution, we also strive to follow ethical business practices and to act as good stewards of the resources made available to us.
Introduction to the University of Connecticut Code of Conduct
In all its endeavors, the University of Connecticut is dedicated to excellence that is demonstrated through national and international recognition. As Connecticut’s public research, land-grant and sea-grant university, through freedom of academic inquiry and expression, we create and disseminate knowledge by means of scholarly and creative achievements, graduate and professional education, and public engagement and service. Through our focus on teaching and learning, the University helps every student grow intellectually and become a contributing member of the state, national and world communities. Through teaching, research, engagement and service, we embrace diversity and cultivate leadership, integrity and engage citizenship in our students, faculty, staff and alumni. As our state’s flagship public land and sea grant institution, we promote the health and well being of Connecticut’s citizens through enhancing the social, economic, cultural and natural environments of the state and beyond.
If you are faced with an ethical issue, you should consult this Code of Conduct as well as current University policies and procedures. You are responsible and accountable for addressing your ethical dilemmas. Consultation with your supervisor, manager, other appropriate colleagues, or the Office of Audit, Compliance and Ethics are avenues available to employees.
The Code of Conduct includes “Questions to Ask Yourself" after each set of Standards. These questions are intended to be thought provoking and assist employees by providing examples of matters that each of us may face during our employment with the University. For guidance regarding individual situations that relate to any of these or other questions, please feel free to contact the Office of Audit, Compliance and Ethics.
The University of Connecticut values all members of its community and recognizes that each person contributes to the overall success of the institution. The University further recognizes that it is through the efforts of its faculty, administrators and staff that it achieves national and international prominence and delivers a world class education to its students. The culture of the University is one of respect, civility, trust, cooperation and collaboration among all its members. We believe all members of the University community are entitled to an environment that ensures collegiality and mutual respect.
Conduct of Faculty, Administrators and Staff
- Members of the University community shall perform their duties in a fair and ethical manner in accordance with established policies, procedures and regulations.
- Members of the University community shall carry out their duties with professionalism. The University supports the efforts of its faculty, administrators and staff to achieve and maintain professional standards.
- The University provides equal opportunity and access to its employment, programs, benefits and services.
- Supervisors have a particular responsibility to support the Code of Conduct and to demonstrate compliance within their units.
- Relationships of an inappropriate personal nature between supervisors and those they supervise are prohibited.
- The University values an environment that promotes a spirit of civility and collegiality, while fostering open and constructive intellectual debate.
- All members of the University community have a responsibility to treat each other with consideration and respect. Managers and supervisors have an elevated responsibility to demonstrate these behaviors and support their expression in the workplace.
- Engaging in behaviors that harass, intimidate, bully, threaten or harm another member of the University community does not support a respectful and civil work environment.
- The University encourages and respects diversity within the university community and does not allow discrimination on the basis of age, race, national origin, religion, disability, sex, sexual orientation or any other characteristic protected by law in any activity or operation of the institution.
- The University affirms its dedication to foster a community that condemns all forms of discrimination or acts of intolerance including sexual harassment, intimidation and retaliation.
- Confidentiality of faculty, staff, patient and student records is respected and maintained in accordance with University policies and procedures, federal laws and state regulations. We use such records for legitimate purposes only and in accordance with proper authorization.
- The University’s computer and telecommunication networks are University resources that are provided to employees, students and volunteers to allow them to carry out the functions of the institution. Those who use the computer and telecommunication networks are responsible for the appropriate use of these resources. We understand, support and abide by the policies concerning the ethical and responsible use of computers and electronic information at the University of Connecticut.
- The University of Connecticut Office of Audit, Compliance and Ethics strives to ensure that we meet the highest possible standards where relevant federal, state and local regulations, laws and guidelines are concerned. This office supports ethical conduct by all faculty, administrators and staff and requires ongoing monitoring of policies, procedures and practices. Education is a key component of this program.
Health and Safety
- We are responsible for complying with all workplace safety and health regulations and will report unsafe conditions, equipment or practices to appropriate University officials, as required by law.
Conflict of Interest
- We, as employees of the State of Connecticut, adhere to the guidelines set forth in the Connecticut Code of Ethics for Public Officials, as well as the University’s Guide to the State Code of Ethics.
- We will not engage in outside activities which will create an actual conflict of interest and will strive to avoid the appearance of a conflict. If faced with a potential conflict of interest, members of the University community shall disclose the nature of the conflict to the appropriate parties.
- We do not accept gifts, including food and beverage, from vendors, lobbyists or any other person or entity that is doing business with or seeking to do business with the University unless permitted under the Connecticut Code of Ethics for Public Officials.
- We do not accept secondary employment that will impair our independence of judgment as to our official duties or which will require us to disclose confidential information.
- We will not use our state positions for personal financial gain beyond our official compensation, or for the financial benefit of our family members or domestic partners.
- We will not use state resources for personal use or for use unrelated to our University responsibilities.
Questions to Ask Yourself
- Have I treated others as they wish to be treated?
- Do I make discriminatory and harassing statements?
- Have I used my position to intimidate or isolate others?
- As a faculty member or staff member, should I accept a gift from a student?
- Do I frequently use my University telephone for personal phone calls?
- Do I use my contacts at the University to help my outside business?
- Do my outside professional activities create an appearance of a conflict of interest?
- Do I maintain appropriate professional relationships with students, colleagues, patients, clients and customers?
- Have I used my position to gain employment for a family member?
- Even if I have access to certain records, do I have the authority to view them and/or distribute them to others?
- Do I know what to do if I think that a University record has been accessed inappropriately by someone inside or outside the University?
- Do I take shortcuts that create a safety hazard?
The University of Connecticut recognizes education as one of its primary missions and strives to maintain a professional environment conducive to the development of its students. To that end, the University believes that the purposes of an educational institution are best served by attracting and developing scholars of proven professional and personal competence and integrity and by assuring those teachers and scholars freedom to expand human knowledge and understanding.
- We educate students from a wide range of backgrounds and respect differences in each individual’s heritage and goals.
- We respect the individual choices that students make for career paths.
- We respect each student as a valuable individual regardless of age, race, color, nationality, ethnicity, ancestry, marital status, gender, disability, religion, sexual orientation or personal beliefs.
- We acknowledge and support students' rights to question faculty members, the administration and staff in good faith.
- We comply with all applicable statutes and regulations.
Student conduct is governed by the applicable codes of conduct and professional standards of conduct adopted by their schools. While this Code applies primarily to faculty, administrators and staff, its underlying principles are, however, common to codes and regulations governing students.
The Division of Athletics operates a broad-based program of intercollegiate athletics and recreational and intramural opportunities that reflect the ethical philosophy of the University, the interest of the student body and the desires of the University’s internal and external constituencies.
- We offer student-athletes the opportunity to excel in academic achievement and athletic accomplishments.
- We foster among our students a sense of citizenship, leadership and social responsibility and encourage adherence to the highest standards of integrity and ethics. We promote principles of good sportsmanship, honesty and fiscal responsibility in compliance with University, state, National Collegiate Athletic Association (NCAA) and conference regulations. 10
- We promote and support the University’s comprehensive commitment to diversity and equity, providing equitable opportunity for all students and staff, including women and members of minority groups.
Questions to Ask Yourself
- Do I foster an environment that is conducive to learning?
- Am I providing each student an equal opportunity to learn?
- Do I react negatively when students challenge or critique my interpretation of source material?
- Do I protect the privacy of each student’s academic record and personal information?
- Are my grading practices fair and understood by all of my students?
- Do I regularly update my teaching materials?
- Am I a role model for my students regarding professional values?
- Do I acknowledge and support providing student athletes equitable and appropriate opportunities to excel in academic achievement?
Research Principles and Standards
The University of Connecticut is committed to the highest standards of professional conduct and integrity in research. These standards include honesty, trustworthiness, objectivity, accountability, openness, respect and fairness when dealing with other people, a sense of responsibility towards others and loyalty to the ethical principles espoused by our institution.
The University expects these standards to be maintained by all academic, research and relevant support staff, students and their supervisors and other individuals conducting research or involved in the peer review process within or on behalf of the University. Prompt reporting to the appropriate institutional administrative committees of violations of human subjects' protection, laboratory safety, or humane treatment of animals is expected.
We understand that academic freedom is essential to creating an atmosphere in which scholarship flourishes. Promotion of intellectual freedom is consistent with assuring a climate of integrity and the University has the right and the obligation to inquire into all instances of alleged or apparent misconduct in scholarly activities.
- We properly collect, record and maintain research data.
- We take responsibility for all publications and presentations of which we are author or co-author.
- We appropriately acknowledge, in publications and presentations, those who have contributed to our research.
- We grant access to our research data to co-investigators involved in generating the data.
- We grant reasonable access to our research equipment and resources to other University investigators involved in research.
- We, the University and its faculty, administrators and staff, do not interfere with the research conducted by students or faculty.
- We do not tolerate plagiarism, falsification, or fabrication of research data, or other scientific misconduct.
- We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, when performing studies involving human subjects.
- We respect human research participants and are committed to their safety.
- We protect human subjects by securing institutional review and approval for any research.
- We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
- We engage all human subjects, or their appropriate representatives, before initiating a research protocol, in a meaningful informed consent process including explanations of possible risks and benefits.
- We allow potential or current participants to withdraw from a study at any time without prejudice.
- We notify human subjects in a timely fashion of any serious adverse events associated with a human subjects study.
- We conduct appropriate education and training before initiating a human subjects study.
- We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, regarding the care, transport, maintenance and use of animals.
- We are committed to the humane treatment of animals in research.
- We protect research animals by securing appropriate institutional review and approval for any research. �?We adhere to approved protocols and obtain prospective institutional approval of any changes in those protocols.
- We conduct appropriate education and training before initiating animal research.
- We abide by all federal and state laws and regulations, in addition to the University’s policies and procedures, concerning laboratory safety.
- We seek prior approval of appropriate University committees when research involves hazardous chemical substances, bio-hazardous materials or radioactive materials.
- We properly document, store, handle, transport and dispose of radioactive, bio-hazardous and hazardous chemical materials, pharmaceuticals and investigative drugs.
- We participate in appropriate education and training before initiating studies involving such materials.
- We comply with all workplace safety and health regulations and will report unsafe conditions, equipment or practices to our supervisors or other appropriate University officials.
- We attend required instructional and training sessions when dictated by funding or oversight agencies.
- We use research funds only for their designated purposes.
- We accurately account for time and effort related to research funding.
- We disclose financial conflicts of interest to University administrators and, as appropriate, manage such conflicts in accordance with existing policies and procedures.
- We properly acknowledge sponsorship of research in our publications and presentations.
- We disclose inventions produced from our research to the University so that consideration is given to the protection of intellectual property.
Questions to Ask Yourself
- Do I work safely in the lab?
- Have I received training and approval to use research materials?
- Have I collected data and documented my research accurately?
- Did I face a conflict of interest today? Does it bias my research?
- Do I protect the safety and well-being of my human or animal subjects?
- Did I obtain proper consent from my human subjects?
- Do I respect the privacy of research participants? Do I appropriately protect the confidentiality of their research data?
Public Engagement and Outreach Standards
The primary purpose of public engagement is to serve external constituents in a manner that leads to enhanced teaching and research. Public engagement efforts impact on the reputation of the University. Engaged scholarship, as a component of public engagement, results from public engagement and outreach. It focuses on those activities that promote advanced understanding and creative works in a mutually beneficial manner. Public engagement, which includes outreach and public service, consists of all activities where the University offers its resources, both human and physical, to external constituencies in such a manner where there is a partnership or that engaged scholarship results. These efforts are on behalf of the public good and not for private gain. The term University resource refers to those activities and entities that the University makes available to its various constituencies which may involve a cost to access. As a land and sea grant university, the University of Connecticut is committed to our mission that includes public engagement as measured by the impact of teaching and research on the world outside of the insitution. In the spirit of true partnership, we seek to expand our interactions with groups beyond our campuses in areas of mutual concern and enhance their access to the resources available at the University. In addition to collaborations in the arts and humanities, we encourage constructive partnerships in new areas of interdisciplinary excellence, such as Health and Human Behavior, the Environment, and Human Rights. Th rough broadened access and reciprocal interaction, we realize synergistic outcomes that further strengthen the University and benefi t the people of Connecticut as well as those beyond the state borders.
- We believe the reputation of the University is tied to its responsiveness to the needs of the citizens and communities of the State.
- We reach out to and engage communities in reciprocal partnerships.
- We are respectful of our community members, demonstrate cultural competence in their interactions, and comply with University policies while engaged in and with communities, just as we would on campus.
- We strive for responsible engaged scholarship and community-based programs to the benefi t of communities by involving our partners in the planning, execution and dissemination of the knowledge gained by such programs.
- We translate and disseminate research results to real world applications to address problems.We recognize and respect the knowledge and behaviors of our partners as we work in a collaborative environment.
- We eff ectively communicate these standards and values with the organization.
- We actively engage students in community experiences as part of our service learning priority.
Questions to Ask Yourself
- Have I ensured that the public engagement eff ort is consistent with the University’s mission and vision?
- How do I solicit input regarding community needs when designing, planning, and conducting my engaged scholarship or community-based project?
- How can I work with community members as equal and collaborative partners in all phases of the project, from planning to dissemination of fi ndings, and avoid the perception of using the group for my gain?
- How do I handle the fi ndings of my work to ensure confi dentiality when appropriate?
- Am I culturally sensitive to the diverse needs of community members and partners, starting with the selection and training of my University team members?
- How can I prioritize considerations of diversity when designing, planning and conducting my community-based research or program, identify any barriers to participation and work to ameliorate or eliminate such barriers?
- How will my actions refl ect how the University is viewed in the community?
- How do I manage, use and share resources of the University in a manner that is respectful to partners?
- How do I teach and engage my students in the work of the community as they apply classroom learning to real world situations?
Patient Care Standards
Clinicians associated with the Health Center, Storrs and regional campuses and other University health care facilities provide compassionate primary and specialty health care in an academic environment. We focus on delivering quality patient care and fostering continuous improvement through scientifi c knowledge that is shared with patients, colleagues and the public.
- We, each faculty and staff member involved in patient-related activities, are expected to understand and support the applicable Patient’s Bill of Rights and Responsibilities.
- We strive to deliver health care that is based on contemporary scientific knowledge and technology.
- We provide educational resources and opportunity for consultations with other health care programs to assist our patients in the planning of their treatment.
- We strive to consider the physical, emotional and spiritual needs of our patients in making our treatment recommendations.
- We do not extend or receive payments or benefi ts in exchange for referrals. Our health care and referrals are based on the well-being of and best treatment for our patients.
- Patients have a right to ask members of their health care team about the role of students and residents in their care and to receive complete and accurate information. We explain to our patients the importance of the educational mission at the University as it relates to their treatment.
- We provide our patients with information necessary to make informed health care decisions. Th is includes reviewing medical fi ndings with each patient, as well as discussing alternative treatment options and the associated risks and benefi ts.
- We prepare clear, honest and accurate patient medical documentation in a timely manner. We maintain the confi dentiality of this information in accordance with existing University policies and procedures, federal laws and state regulations, including but not limited to the Health Information Portability and Accountability Act (HIPAA). �?We provide clinical facilities and laboratories to support quality care for our patients. We adhere to appropriate policies and procedures to ensure that we retain certifi cation in all aspects of program function as required by institutional, state and federal regulatory agencies.
Questions to Ask Yourself
- Do I demonstrate respect and compassion for my patients and their families?
- Was the care that I provided today in the best interest of my patients?
- Did I answer my patients' questions to the best of my ability or assist them in obtaining the information they requested?
- Do I offer all of the needed resources and services to my patients or assist them in making a referral to obtain those services?
- Do I respect the privacy of my patients and protect the confidentiality of their health information?
- Did I document my patient care thoroughly and accurately today?
Business, Fiscal and Legal Standards
The University of Connecticut adheres to established business standards in its conduct as an institution of higher education and as a health care provider. We comply with all applicable federal, state and local government laws and regulations and strive to follow ethical business practice standards. We endeavor to conduct all University business with honesty, integrity, accuracy and fairness.
- We strive to make all purchasing decisions based on the best interests of and value to the University. The University follows fair business practices in its contracting.
- We recognize the value of obtaining competitive bids when appropriate, maintaining independence, ascertaining the financial and legal status of vendors and obtaining clear written agreements for services or goods to be purchased.
- We comply with all state guidelines regarding procurement activities. We comply with all laws relating to pricing, competition and business arrangements.
- In the course of doing business, the University creates and receives information that could directly affect the success of its business ventures or those of its current or prospective business partners. If used inappropriately, this information could unduly benefit individuals who have access to such information. The University depends on the ethical business practices and personal integrity of its employees to protect this information from premature or improper use and disclosure.
Physical property and intellectual property, including data
The University’s physical property includes property that is owned by the University but entrusted to individuals or organizational units within the University. Examples include office and departmental equipment and supplies, vehicles, facilities, cash, reports and records, including clinical and billing records in department offices, computer software, electronic files and data, patents, trademarks and service marks.
- We utilize such resources properly and protect property against loss, theft, misuse and waste.
- Research materials, inventions or devices developed through the use of University resources are the property of the University. Rights to such property may be transferred to other parties (such as commercial sponsors) only with express written authorization. Materials subject to copyright are generally not the property of the University.
- Research data are considered the property of the principal investigator or the joint property of collaborating individuals when research data are generated by a principal investigator working in collaboration with one or more faculty colleagues.
- Research data generated by postdoctoral fellows, graduate students, research trainees or others who have had significant intellectual input, shall be considered the joint property of the collaborating individuals.
- The use of any form of intellectual property covered by copyright and license agreements and used for face-to-face, distance teaching purposes or a combination of the two, will comply with copyright law and the terms of the license agreement under which it was obtained. Examples include books, journal articles, newspapers, images, audio, and video in physical or electronic form owned or borrowed by the University or the instructor.
Financial Records and Funding Sources
- We understand that the federal and state governments constitute major funding sources for the University in student financial aid, research and other areas. As such, we acknowledge responsibility for the stewardship of such funds, understanding and complying with federal and state laws and regulations.
- We maintain accurate and timely financial records in accordance with the University’s policies and Generally Accepted Accounting Principles. We use appropriate internal financial controls to safeguard assets and to ensure compliance with all internal and external accounting rules and regulations. We cooperate fully with internal and external auditors and regulatory agencies during examinations of all books and records and do not alter or destroy any documents in anticipation of such reviews.
- We, as employees of the University, accurately account for our time and properly document when seeking reimbursement for work-related expenses.
- We charge and bill for patient care services in accordance with third party regulations and applicable state and federal laws. We bill for medically appropriate services that are clearly and accurately documented in the medical record. We submit claims for services in a timely manner. We maintain accurate patient accounts and promptly correct billing errors.
- We acknowledge that clinical care providers, coding personnel and billing staff have a collective responsibility to understand the third party regulations and federal and state laws governing the services they are providing.
Questions to Ask Yourself
- Did I document my work clearly, honestly and accurately?
- When I sign a document, do I understand what I am signing?
- Do I understand when the competitive bidding process must be used?
- Have I signed a contract without obtaining proper authorization?
- Am I wasteful of University supplies?
- Was I honest with my coding of patient visits today?
- Do I share my computer password with others?
External Relations and University Advancement
Government relations and political activity
- We depend, as a public institution, upon the support and trust of federal and state officials.
- We will not make representations on behalf of the University without official authorization.
- We do not engage in partisan political activities while on state time nor will we use University resources for the purposes of influencing a political election.
- We adhere to federal and state laws which provide guidance for the political activities of the University employees.
Public access to University information
- We facilitate accurate, ethical and timely news coverage of significant programs and the achievements of faculty, administrators, staff, students and alumni.
- We comply with all federal and state laws and regulations as well as all University polices regarding the release of information about activities of the University, or its employees, students, volunteers, patients or research subjects, carefully balancing privacy rights with the public’s interest.
- We recognize that the process of raising charitable funds requires ethical and sensitive interactions with prospective and current donors. Although we may release general information about alumni or other supporters, we respect an individual donor’s intent and honor all requests for anonymity.
- We recognize that the primary responsibility for development of prospective donors lies with the University of Connecticut Foundation. The Foundation works in cooperation with offices and departments across the University but is organizationally independent of the University itself.
- We acknowledge that University Communications is the University’s primary and official liaison to the news media- international, national, regional, state and local-and that this department is responsible for initiating, developing and maintaining effective, productive and beneficial relations with the news media in communicating University news and in responding to media requests.
- We respect the individual freedom of faculty, staff and administrators to express their personal opinions on University actions and policies, while also recognizing that University Communications is responsible for coordinating official University comment on all matters regarding the institution.
- We understand that the University encourages its faculty, staff and administrators to serve as members of community panels, boards, civic organizations, professional associations and other similar voluntary associations. An employee assuming such a role is not acting as a spokesperson of the University.
- We recognize that University Communications is responsible for establishing and maintaining the University’s graphic standards and that specific standards apply to the use of the University’s logos and seals.
- We understand that the University has legal rights regarding the use of its name, logos and seals and protected trademarks.
Questions to Ask Yourself
- Have I referred media requests to University Communications?
- Should I talk “off the record" to a reporter?
- When is it appropriate to talk to the media about my research or to comment on the research of others? �?Should I speak on behalf of the University to government officials regarding University matters?
- Can I be identified as a University employee in my political or charitable activities?
- Do I maintain clear boundaries between my professional role and my personal activities that are unrelated to the University?
Resources, Additional Information and Reporting
The University has established the Office of Audit, Compliance and Ethics to oversee its internal audit and compliance programs and to ensure compliance with applicable laws, regulations, policies and procedures.
Obtaining Additional Information, Reporting Compliance Concerns and Non-Retaliation Policy
- For additional information please refer to the appropriate website or contact the office at the phone numbers or email addresses noted below. If you wish to report suspected violations of laws, regulations, rules, policies, procedures, ethics or any other information you feel uncomfortable reporting to your supervisor or faculty administrator, you may also contact the Office of Audit, Compliance and Ethics directly using the phone numbers or email addresses listed below.
Storrs and Regional Campuses:
9 Walter’s Avenue, Unit 5084
Storrs, CT 06269-5084
Phone: (860) 486-4526
Fax: (860) 679-1608 E
263 Farmington Avenue
Farmington, CT 06030
Phone: (860) 679-4180
Fax: (860) 486-4527
- If you wish to report a concern or a suspected violation anonymously you may contact the University’s REPORTLINE using the contact information below. The REPORTLINE is operated by a private (non-University) company. No effort is made to identify the person reporting and no trace of the call is performed. Information received is given to the Compliance Officer for appropriate action. This service is available 24 hours a day, 7 days a week and is staffed by independent specialists trained to obtain complete and accurate information in a confidential manner. If you wish, you may obtain information about the Compliance Office response to your call by following up with the REPORTLINE at a later date. To contact the REPORTLINE:
Storrs and Regional Campuses
Web reporting address: https://www.compliance-helpline.com/uconncares.jsp
Other Reporting Options
- State Auditors of Public Accounts
The Whistle Blower Act, Section 4-61dd of the Connecticut General Statutes, authorizes the Auditors of Public Accounts to receive information concerning matters involving corruption, unethical practices, violation of State laws or regulations, mismanagement, gross waste of funds, abuse of authority or danger to the public safety occurring in any State department or agency. Upon receiving such information the Auditors are required to review such matters and report their findings and any recommendations to the Attorney General. The Auditors shall not, after receipt of any information from a person under the provisions of this section, disclose the identity of such person without his/her consent unless the Auditors determine that such disclosure is unavoidable during the course of the review. You can file a complaint with the Auditors of Public Accounts by calling (860) 566-1435 or toll free at (800) 797-1702. Website: www.state.ct.us/apa
- Federal False Claims Act (31 U.S.C. § 3729-3733)
This act permits a person with knowledge of fraud against the federal government to file a lawsuit on behalf of the government against those that committed the fraud. The person filing the lawsuit is also known as the “whistleblower" or “qui tam" plaintiff. The “qui tam" plaintiff must notify the United States Department of Justice (DOJ) of all information regarding the fraud. If the DOJ takes the case and fraud is proven the “qui tam"plaintiff is entitled to a portion of the money recovered by the federal government. Under the False Claims Act the “qui tam"plaintiff is protected from retaliation that may result from his or her involvement in the case. This is known as Whistleblower Protection.
- University policy prohibits retaliation if you report in good faith a compliance concern to any supervisor, faculty, administrator, the Compliance Office, the REPORTLINE or any appropriate agency outside of the University. If you feel that you have been subject to retaliation, you should contact the Compliance Office immediately. The Compliance Office will respond to all reports in a timely manner in order to resolve any non-compliance and to educate regarding compliance concerns.
Code of Ethics and Business Conduct
AICPA Code of Conduct
AGDA Code of Ethics
Why graphic design needs a Code of Ethics
What use is a Code of Ethics to a graphic designer or related professional? Isn't it just another boring slab of legalese, more pompous than pertinent? We hope not! Our Code of Ethics is here to establish what constitutes 'fair play'. It is intended to provide protection for both designers and clients from unethical business practices and the havoc that can be caused by unwitting ignorance.
By detailing (in something close to plain English) professional conduct expectations in the key aspects of client/designer/subcontractor relationships, AGDA provides national benchmarks for professional service and conduct in the graphic design profession.
The Code of Ethics is a powerful tool in dealing with destructive practices such as competitive free pitching, to which AGDA is unequivocally opposed.
The Code of Ethics will also serve to enhance clients' understanding of the how/what/why of graphic design.
Purpose of this Code
The purpose of this Code of Ethics ('the Code') is to provide AGDA Members ('Member/s') with internationally accepted standards of professional ethics and conduct. This Code contains guidelines for the conduct of Members in fulfilling their professional obligation. Members agree to be bound by these guidelines. This Code was nationally ratified by the AGDA membership in October 1996.
This Code of Ethics is based on the Model Code of Professional Conduct for Designers published in 1987 by ICOGRADA (International Council of Graphic Design Associations), ICSID (International Council of Societies of Industrial Design) and IFI (International Federation of Interior Architects/Interior Designers).
A Member, supplier or client may call upon AGDA for arbitration of a dispute regarding a Member's fulfilment of professional obligation. The guidelines in this Code will be used by an appointed AGDA Grievance Committee as the basis for reaching a decision and making a recommendation.
A Grievance Committee will consist of local, non-partisan industry experts, with the selected committee list being submitted to involved parties for approval. The Grievance Committee is not intended to offer legal advice, but to act in an impartial manner to clarify issues and recommend equitable and amiable resolutions to conflicts. All proceedings are held in the strictest confidence, but from time to time, AGDA will publish case histories without real names in the interest to educating Members and the public about professional conduct.
1. A Member's responsibilities when practicing in a country other than Australia
AGDA requires that Members accept the Code and Practice of the appropriate design association within that country (contact your local AGDA Secretariat for a current listing of overseas design associations). (Link to Contacts)
2. A Member's responsibilities to the community
2.1 The environment
A Member shall work in a manner so that as little harm (direct or indirect) as possible is caused to the natural environment.
2.2 Conflict of interest
A Member shall not knowingly accept a position or commission in which a personal interest conflicts with professional obligation and duty.
2.3 Professional conduct
A Member shall not act in a manner that compromises the status of the design profession.
2.4 Design standards and support of AGDA
A Member shall encourage high standards of design and professional conduct, and support the aims of AGDA.
3. A Member's responsibilities to the client
3.1 Client's best interests
A Member shall always act in the best interests of the client, within the limitations of professional obligation and the guidelines of this Code.
3.2 Conflict of interest
A Member shall not knowingly accept commissions on directly competing products or services without first informing, and obtaining written consent from, the clients. Directly competing products or services are those where the possibility of 'insider' information could give involved parties material and unfair advantage.
A Member shall hold confidential all information of a client's organisation and activities that is not available through public records. A Member accepts this same responsibility for all subordinates involved with the client's projects.
4. A Member's responsibilities to other designers
4.1 Predatory pricing (free pitching)
AGDA discourages members from predatory pricing practices such as free pitching, loss leading and other pricing below break-even. Members should be aware that such practices will damage the economic viability of their business.
4.2 Existing commissions
A Member shall not knowingly accept a commission to work on a project for which there is an existing designer without first informing the other designer. This clause applies specifically to projects, and not to clients whose design needs require using a number of designers for different projects or accounts. As a matter of professional courtesy, AGDA encourages its Members to inform a client's existing designer/s if a Member receives a commission from that client.
4.3 Plagiarism and breach of copyright
A Member shall not, under instruction from a client or independently, plagiarise work or knowingly breach copyright.
4.4 Criticism of another designer's work A Member shall be fair in the criticism of another designer's work. A Member shall not belittle or denigrate the work or reputation of another designer.
5.1 Presentations for securing commissions
Preliminary to securing a commission, a Member is should present a proposal in writing which covers: an understanding of the brief an outline of how the project will be undertaken an estimate of fees In addition to the above, a Member may also present: examples of previous work qualifications and details of experience of project team members
5.2 Accepting a commission
Prior to accepting a commission, a Member shall provide in writing to the client, and obtain written consent from the client for: an accurate description of the work to be carried out an estimate of fees and charges, or the basis on which these are to be calculated the terms and conditions of the design work's undertaking, completion and payment disclosures, as set out in this Code, relating to any other financial or other interests the Member may have in the project.
A Member shall inform, and obtain consent from, a client before subcontracting principal design work. For design-related subcontracting, a Member shall inform the client of the scope of subcontracted work and the terms of subcontracting, including any fees or charges that will be applied by the Member to the subcontractor's fees and expenses.
6.1 Fees and charges
A Member shall charge a fee, royalty, salary or other agreed upon form of remuneration. A Member may, after informing the client, add a reasonable handling and administration charge to all reimbursable items that pass through the Member's accounts. A Member should, in the case of handling and administration charges, inform the client of the existence and nature of these charges.
6.2 Free pitching
AGDA is unequivocally opposed to the unfair manipulation of designers with the aim of garnering unpaid work (commonly known as 'free pitching'). Client practices which do damage to a member's business are those that award projects or commissions on the basis of the commissioner's acceptance of unpaid design submissions (eg. unpaid competitive tendering or speculative work)
6.3 Fee reductions and non-paying commissions
A Member may provide a fee reduction for, or a donation of service to, a charitable or non-profit organisation.
6.4 Financial interests in a project other than declared fees
Where the Member is in a position to receive financial or another form of material benefit from a company or individual who may benefit from the Member's recommendations to a client, the Member must inform the client of this situation in advance of making the recommendation.
6.5 Selection of another designer
A Member involved in assisting a client in the selection of another designer shall not accept any form of payment from the designer recommended.
7. Design competitions
A Member shall not take part in any design competition if the terms of the competition are not approved by AGDA. AGDA bases its assessments on the International Competition Guidelines published by ICOGRADA (International Council of Graphic Design Associations). A Member or organiser of a competition can contact AGDA to review a competition's terms and provide recommendations and/or approval.
8. Self promotion and publicity
A Member shall not use false, misleading or deceptive statements in advertising or publicity material. The content must be fair to clients and other designers, and must not compromise the status of the design profession.
A Member shall claim authorship to the extent of the involvement in a project. Where a project is a collaborative effort, each designer/consultant shall be credited for specific areas of authorship. A Member shall neither claim credit for, nor allow a client to associate their name with, a project which has been so changed as to no longer substantially be the original work of the Member.
8.3 Use of a Member's name in the promotion of a product or service
A Member's name may be used in the promotion of articles designed or services provided, but only in a manner appropriate to the status of the design profession.
Ethical Guidelines for Good Research Practice
Social anthropologists carry out their professional research in many places around the world; some where they are 'at home' and others where they are in some way 'foreign'. Anthropological scholarship occurs within a variety of economic, cultural, legal and political settings. As professionals and as citizens, they need to consider the effects of their involvement with, and consequences of their work for the following: the individuals and groups among whom they do their fieldwork (their research participants or 'subjects'); their colleagues and the discipline; collaborating researchers; sponsors, funders, employers and gatekeepers; their own and host governments; and other interest groups and the wider society in the countries in which they work.
Anthropologists, like other social researchers, are faced increasingly with competing duties, obligations and conflicts of interest, with the need to make implicit or explicit choices between their own values and between the interests of different individuals and groups. Ethical and legal dilemmas occur at all stages of research: in the selection of topic, area or population, choice of sponsor and source of funding, in negotiating access, making 'research bargains' and during the research itself while conducting fieldwork, including the interpretation and analysis of results, the publication of findings and the disposal of data. Anthropologists have a responsibility to anticipate problems and insofar as is possible to resolve them without harming either the research participants or the scholarly community. They should do their utmost to ensure that they leave a research field in a state which permits future access by other researchers. As members of a discipline committed to the pursuit of knowledge and the public disclosure of findings, they should strive to maintain integrity in the conduct of anthropological research. This ethics code applies to anthropological work whether studying 'up' and/or 'down', with persons and/or animals, within and outside the UK as well as in cyberspace.
The ethnographic method – the process through which theory is developed on the basis of empirical data collected – is the dominant mode through which anthropology is practised. Ethnographic methods cover a range of research practices and methods often including long/short-term/multi-sited/repeated fieldwork/visits. These ethical guidelines address the stages of preparation, the process of fieldwork and the writing procedure. Within fieldwork, participant observation has been considered by anthropologists as one of the core methods. This is a holistic method of research which is usually carried out over a period of time and can be conducted with a wide variety of communities and groups. The contexts for research can include economic, political, legal, medical settings and concerns as well as religious, gender, and kinship dimensions, among many others. The range of participants is also, as a result, varied. Participant observation is inductive and has the potential for uncovering unexpected links between different domains of social life. Accordingly, a degree of flexibility in research design that allows modification of topic focus - following the initial formulation of a research question - is required. Participant observation includes engagement with and observation of various forms of participatory activities specific to the group being studied, usually in both public and private settings. Fieldwork is also carried out by means of casual conversations (with a wide range of participants, some of whom are wellknown and seen regularly, others during fleeting encounters), interviews (usually open-ended, qualitative and in-depth), surveys, audio and video recording, sometimes supplemented by subsequent co-viewing with participants. The methods can vary from the informal and unstructured (such as participant observation, conversations) through to structured methods (such as interviews, surveys, audio-visual recordings).
Participant observation involves certain key ethical principles:
- Participants should be made aware of the presence and purpose of the researcher whenever reasonably practicable. Researchers should inform participants of their research in the most appropriate way depending on the context of the research.
- Fieldnotes (and other forms of personal data) are predominantly private barring legal exceptions. This is the most important way in which confidentiality and the anonymity of subjects is ensured. Anthropologists have a duty to protect all original records of their research from unauthorised access. They also have a duty to ensure that nothing that they publish or otherwise make public, through textual or audio-visual media, would permit identification of individuals that would put their welfare or security at risk.
- Given the methods used during fieldwork, and depending on the nature of the project, the researcher may be able to provide only rough approximations in advance (for example, to various institutional Ethics committees including those to do with the university, National Health Service etc.) of some of the likely participants an anthropologist will observe or converse with during fieldwork and some of the likely scenarios in which consent will be sought. As a result, it may be difficult and/or artificial to prepare distinct data collection instruments for approval in advance. Given the open-ended and often long-term nature of fieldwork, ethical decision-making has to be undertaken repeatedly throughout the research and in response to specific circumstances.
- Many of those participating in public events observed by the anthropologist will not be known to him or her. This is particularly the case for strangers visiting the community (a term that could also include employees of government agencies, multinational corporations, schools, hospitals among others) being studied; or in research on mobile groups (which could involve pastoral and nomadic groups, refugees or expatriate and corporate elites) who move around for various reasons (such as subsistence, ritual celebrations, pilgrimage, corporate meetings, wartime displacements) to other places; or in studies of large institutions. In such situations, the anthropologists should take all practicable steps to be introduced by local participants and identify him/herself as a researcher. Not everyone observed or photographed, especially in large crowds, will be known. Large-scale events (such as religious festivals, political rallies or mass protests) are clearly legitimate and necessary foci of anthropological study, but should be subject to various ethical considerations. Hence due sensitivity to those involved in large-scale events and necessary observation of ethical standards with regard to the sensibilities and security of the participants needs to be kept in mind depending on the nature of the event.
- Many of the communities studied by anthropologists are highly suspicious of formal bureaucratic procedures and often of their state or local forms of the state. Under these circumstances, requests for signatures on printed forms are liable to arouse suspicion and therefore standard procedures for obtaining written consent can be problematic. It is possible and appropriate, however, to obtain informed verbal consent. In working with informants with limited literacy or with learning difficulties that might render informed consent as commonly understood problematic, it may be appropriate to give people the chance to discuss their consent to an interview with friends, family or other trusted acquaintances. Repeated checking with informants during the research process, can ensure that the continuity of consent is maintained.
- In some cases, consent will initially need to be sought from individual gatekeepers such as community leaders and officials: chiefs, local councillors, headmen, hospital consultants, trade union leaders, etc or from collective decision-making bodies such as community or neighbourhood assemblies. In addition to needing to negotiate access to the field through such "gatekeepers", it will often be desirable to supplement the informed consent of collective bodies with that of individuals, particularly where substantial sectors of the local society are excluded from collective decision-making but are also subjects of the research. By the same token, in all settings further consent may need to be negotiated as the research advances and new fields of inquiry open up.
- Photography (both stills and film) is a very important tool of anthropological inquiry. Filming should always be overt. Moreover, in the case of large public events it is likely that not everyone photographed/filmed will have the chance to give verbal consent. In such cases the researchers should do all that is possible in his/her powers to not compromise people's identities or security in public presentations of the material.
In light of these considerations, the weight of responsibility for adherence to good ethical conduct is on the anthropological researcher. Ethics Committees need to recognise the diversity of methods of ethnographic research. For anthropology, once the research is completed the ethics of representations are a major issue. The principles outlined below are intended to guide anthropologists not only in the way they conduct fieldwork but in the way they represent and publish their results to wider audiences.
To these ends the Association has adopted the following set of ethical guidelines to which individual members, other anthropologists should subscribe. They follow the educational model for professional codes, aiming to alert researchers to issues that raise ethical concerns or to potential problems and conflicts of interests that might arise in the research process. They are intended to provide a practical framework for anthropologists to make informed decisions about their own behaviour and involvement, and to help them communicate their professional positions more clearly to the other parties involved in or affected by their research activities. Anthropologists requiring permission from local bureaucracies for the purpose of their research (particularly on sensitive topics like research on children) might, however, need to adhere to the ethics procedure of the institution from which permission is being sought. The ASA does not adjudicate claims regarding unethical behaviour. Rather than intervening, the ASA can act as a forum for discussion among parties to a disagreement over ethics. Anthropological researchers should expect to encounter ethical dilemmas at every stage of their work, and should make good-faith efforts to identify potential ethical claims and conflicts in advance when preparing proposals and as projects proceed. Persons using the ASA guidelines to help them make ethical choices or for teaching are encouraged to seek out illustrative examples and appropriate case studies to enrich their knowledge base.
I. Relations with and responsibilities towards research participants
The close and often lengthy association of anthropologists with the communities/cultures/societies among whom they carry out research entails personal and moral relationships, trust and reciprocity between the researcher and research participants; it also entails recognition of power differentials between them.
1) Protecting research participants and honouring trust: Anthropologists should endeavour to protect the physical, social and psychological well-being of those with whom they conduct their study and to respect their rights, interests, sensitivities and privacy, other than in the most exceptional of circumstances. It would also be important to keep in mind the ethical responsibilities to non-human research subjects.
a) The ASA maintains that their paramount obligation is to their research participants and that when there is conflict, the interests and rights of those studied should come first. This means that anthropologists must reflect particularly deeply on the likely impacts on the communities/cultures/societies they are studying; of any research, consultancy or other services that they might offer or be asked to provide to national/supra-national or foreign states or to non-state entities (such as transnational corporations, law enforcement agencies, NGOs or charities) that intervene or are seeking to intervene in the lives of those communities/cultures/societies. Work for state or non-state organisations that is covert, and therefore breaches relations of trust and openness, is especially problematic. Overt work that is only possible because the participants are subject to coercion is also likely to breach basic ethical standards.
b) Under some research conditions, particularly those involving contracted research, it may not be possible to fully guarantee research participants' interests. In such cases anthropologists would be well-advised to consider in advance whether they should pursue such research.
2) Anticipating harms: Anthropologists should be sensitive to the possible consequences of their work and should endeavour to guard against predictably harmful effects. Consent from subjects does not absolve anthropologists from their obligation to protect research participants as far as possible against any potential harmful effects of research:
a) The researcher should try to minimise disturbances both to subjects themselves and to the subjects' relationships with their environment. Even though research participants may be immediately protected by the device of anonymity, the researcher should try to anticipate the long-term effects on individuals or groups as a result of the research;
b) Anthropologists may sometimes be better placed than (at the least, some of) their informants to anticipate the possible repercussions of their research both for the immediate participants and for other members of the research population or the wider society. In certain political contexts, some groups, for example, religious or ethnic minorities, may be particularly vulnerable and it may be necessary to withhold data from publication or even to refrain from studying them at all.
3) Avoiding undue intrusion: Anthropologists should be aware of the intrusive potential of some of their enquiries and methods:
a) Like other social researchers, they have no special entitlement to study all phenomena; and the advancement of knowledge and the pursuit of information are not in themselves sufficient justifications for overriding the values and ignoring the interests of those studied;
b) They should be aware that for research participants becoming the subject of anthropological description and interpretations can be a welcome experience, but it can also be a disturbing one. In many of the social scientific enquiries that have caused controversy, problems have not arisen because participants have suffered directly or indirectly any actual harm. Rather, concerns have resulted from participants' feelings of having suffered an intrusion into private and personal domains, or of having been wronged (for example, by acquiring self-knowledge which they did not seek or want). Where feasible, participants should also be made aware that they can withdraw from the research at any time.
4) Negotiating informed consent: Inquiries involving human subjects should be based on the freely given informed consent of subjects. The principle of informed consent expresses the belief in the need for truthful and respectful exchanges between social researchers and the people with whom they study.
a) Negotiating consent entails communicating information likely to be material to a person's willingness to participate, such as: the purpose(s) of the study and the anticipated consequences of the research; the identity of funders and sponsors; the anticipated uses of the data; possible benefits of the study and harm or discomfort that might affect participants; issues relating to data storage and security; and including limits to the degree of anonymity and confidentiality which may be afforded to informants and subjects. These can be communicated verbally, particularly to those participants with whom the anthropologist has close and continuing relations.
b) Conditions which constitute an absence of consent: consent made after the research is completed and publicly made available is not meaningful consent at all. Where subjects are legally compelled (e.g., by their employer or government) to participate in a piece of research, consent cannot be said to have been meaningfully given by subjects, and anthropologists are advised not to pursue that piece of work. However, as has been noted above, in the case of exceptional circumstances such as large public events - especially where photographs are taken - consent sometimes might be sought after the event as it is often not possible to seek advance consent. Although it will not always be possible to obtain formal consent, reasonably practicable steps to do so should be taken.
c) Consent in ethnographic research is a process, not a one-off event, due to its long-term and open-ended qualities. Consent may require renegotiation over time; it is an issue to which the anthropologist should return periodically. Depending on the research project, researchers may only be able to provide a rough approximation of some of the likely scenarios in which consent might be sought. Thus continuous reflection on ethical issues and conduct is necessary.
d) When audio-visual media is to be used, be it merely for data-gathering or for broader representational purposes such as producing ethnographic films or photographic essays, the principal research subjects should be made aware of the technical capacities of these media and should be free to reject their use. These conditions should generally apply in public spaces as well as in private spaces where there is a reasonable expectation of privacy. And anthropologists must take steps at the beginning of fieldwork to sensitise themselves to local norms that may embody different ideas about the private and public from those of the anthropologist's' own society.
e) Anthropologists engaged in cyber ethnography or other forms of research that involve the use of electronic texts, images and/or audio-recordings already in the public domain and/or available through fora such as blogs, chatrooms, social media sites etc., should remain sensitive to the possible implications of re-using those electronic texts, images and sounds, not only in terms of ethical responsibilities to the subjects but also in relation to the Intellectual Property Rights held either by the subjects themselves or by those who created the images or recordings in the first place. It is important to note that the very notion of public domain (given the issue of membership for some sites and corporate ownership in social networking sites) is an evolving, shifting phenomenon and hence so is cyber ethnography and its ethical implications.
f) When information is being collected from proxies, care should be taken not to infringe the 'private space' of the subject or the relationship between subject and proxy; and if there are indications that the person concerned would object to certain information being disclosed, such information should not be sought by proxy.
g) The long period over which anthropologists make use of their data and the possibility that unforeseen uses or theoretical interests may arise in the future may need to be conveyed to participants, as should any likelihood that the data may be shared (in some form) with other colleagues or be made available to sponsors, funders or other interested parties, or deposited in archives.
5) Rights to confidentiality and anonymity: informants and other research participants should have the right to remain anonymous and to have their rights to privacy and confidentiality respected. However, privacy and confidentiality present anthropologists with particularly difficult problems given the cultural and legal variations between societies and the various ways in which the real interests or research role of the ethnographer may not fully be realised by some or all of participants or may even become invisible over time.
a) Care should be taken not to infringe uninvited upon the 'private space' (as locally defined) of an individual or group;
b) As far as is possible researchers should anticipate potential threats to confidentiality and anonymity. They should consider whether it is necessary even as a matter of propriety to record certain information at all; take appropriate measures relating to the storage and security of records during and after fieldwork; and use where appropriate such means as the removal of identifiers, the use of pseudonyms and other technical solutions to the problems of privacy in field records and in oral and written forms of data dissemination (whether or not this is enjoined by law or administrative regulation);
c) Researchers should endeavour to anticipate problems likely to compromise anonymity; but they should make clear to participants that it may not be possible in field notes and other records or publications totally to conceal identities, and that the anonymity afforded or promised to individuals, families or other groups may also be unintentionally compromised. A particular configuration of attributes can frequently identify an individual beyond reasonable doubt; and it is particularly difficult to disguise, say, office-holders, organizations, public agencies, ethnic groups, religious denominations or other collectivities without so distorting the data as to compromise scholarly accuracy and integrity;
d) If guarantees of privacy and confidentiality are made, they should be honoured unless there are clear and overriding ethical reasons not to do so. Confidential information should be treated as such by the anthropologist even when it enjoys no legal protection or privilege, and other people who have access to the data should likewise be made aware of their obligations; but conversely participants should be made aware that it is rarely, if at all, legally possible to ensure total confidentiality or to completely protect the privacy of records. Fieldnotes and other data should not be archived in raw form if this infringes either the promise of confidentiality and anonymity made to participants, or the stated reasons for the research on which informed consent was agreed. Extended embargo periods may provide a way of securing the material for future researchers, including those from source communities, while honouring present commitments. In the longer term, it might be proper to make available fieldnotes and other research material for use by other researchers e.g. by including them in relevant archives. Anthropologists should make this clear when securing informed consent. Anthropologists should be cognisant that they might not be able to protect their fieldnotes to the fullest extent and hence care must be taken as to how data is recorded.
e) Anthropologists should similarly respect the measures taken by other researchers to maintain the anonymity of their research field and participants.
6) Fair return for assistance: There should be no economic exploitation of individual informants, translators, groups, animals and research participants or cultural or biological materials; fair return should be made for their help and services.
7) Participants' intellectual property rights: It should be recognised that research participants have contractual and/or legal interests and rights in data, recordings and publications, although rights will vary according to agreements and legal jurisdiction.
a) It is the obligation of the interviewer to inform the interviewee of their rights under any copyright or data protection laws of the country where research takes place, and the interviewer should indicate beforehand any uses to which the anthropological use of interview methods is likely to be put (e.g., research, educational use, publication, broadcasting etc).
b) Under the UK Copyright, Designs and Patents Act (1988), researchers making audio or video recordings should obtain 'copyright clearance' from interviewees if recordings are to be publicly broadcast or deposited in public archives. Any restrictions on use (e.g. time period) or other conditions (e.g. preservation of anonymity) which the interviewee requires should be recorded in writing or can also be done audio-visually as a record of oral consent. This is best done at the time of the interview (the anthropological use of this method), using a standard form. Retrospective clearance is often time-consuming or impossible where the interviewee is deceased or has moved away.
c) Interviewers should clarify before interviewing the extent to which subjects are allowed to see transcripts of interviews, and field notes and to alter the content, withdraw statements, provide additional information or to add glosses on interpretations.
d) Clarification should also be given to subjects regarding the degree to which they will be consulted prior to publication.
8) Participants' involvement in research: As far as is possible anthropologists should try and involve the people from the communities/cultures/societies being studied in the planning and execution of research projects. They should recognise that their obligations to the participants or the host community may not end (indeed should not end, many would argue) with the completion of their fieldwork or research project.
II. Relations with and responsibilities towards sponsors, funders and employers
Anthropologists should attempt to ensure that sponsors, funders and employers appreciate the obligations that they have not only to them, but also to research participants and to professional colleagues.
1) Clarifying roles, rights and obligations: Anthropologists should clarify in advance the respective roles, rights and obligations of sponsor, funder, employer and researcher:
a) They should be careful not to promise or imply acceptance of conditions which would be contrary to professional ethics or competing commitments. Where conflicts seem likely, they should refer sponsors or other interested parties to the relevant portions of the professional guidelines;
b) Anthropologists who work in non-academic settings should be particularly aware of likely constraints on research and publication and of the potentiality for conflict between the aims of the employer, funder or sponsor and the interests of the communities/cultures/societies studied;
c) Where some or all of the research participants are also acting as sponsors and/or funders of the research the potential for conflict between their different roles and interests should be made clear to them.
2) Obligations to sponsors, funders and employers: Anthropologists should recognise their general and specific obligations to sponsors, funders and employers whether these are contractually defined or are only the subject of informal, and often unwritten, agreements. In particular:
a) They should be honest about their qualifications and expertise, about the limitations, advantages and disadvantages of their methods and data, and they should acknowledge the necessity for discretion with confidential information provided by sponsors and employers;
b) They should not conceal personal or other factors which might affect the satisfactory conduct or completion of the proposed research project or contract.
3) Negotiating 'research space': Anthropologists should be careful to clarify, preferably in advance of signing contracts or starting their research, matters relating to their professional domain and to their control over the research project and its products:
a) They are entitled to full disclosure of the sources of funds, personnel and aims of the institution for the purpose(s) of the research project and the disposition of research results;
b) They are entitled to expect from a sponsor, funder or employer a respect for their professional expertise and for the integrity of the data, whether or not these obligations are incorporated in formal contracts. Even when contractual obligations may necessitate the guarding of privileged information, the methods and procedures that have been utilised to produce the published data should not be kept confidential;
c) They should pay particular attention to matters such as: their ability to protect the rights and interests of research participants; their ability to make all ethical decisions in their research; and their own and other parties' rights in data collected, in publications, copyright and royalties.
4) Relations with gatekeepers: Where access to subjects is controlled by a national or local 'gatekeeper', researchers should not devolve their responsibilities onto the gatekeeper. Whilst respecting gatekeepers' legitimate interests, researchers should adhere to the principle of obtaining informed consent directly from subjects once access has been gained. They should be wary of inadvertently disturbing the relationship between subjects and gatekeepers since that will continue long after the researcher has left the field.
III. Relations with, and responsibilities towards, colleagues and the discipline
Anthropologists derive their status and certain privileges of access to research participants and to data not only by virtue of their personal standing but also by virtue of their professional citizenship. In acknowledging membership of a wider anthropological community anthropologists owe various obligations to that community and can expect consideration from it.
1) Individual responsibility: Anthropologists bear responsibility for the good reputation of the discipline and its practitioners. In considering the methods, procedures, content and reporting of their enquiries, their behaviour in the field and relations with research participants and field assistant, they should therefore try to ensure that their activities will not jeopardize future research. Thus, anthropological researchers are subject to the general moral rules of scientific and scholarly conduct: they should not deceive or knowingly misrepresent (e.g. fabricate evidence, falsify, or plagiarise), or attempt to prevent reporting of misconduct, or obstruct the scientific/scholarly research of others.
2) Conflicts of interest and consideration for colleagues: It should be recognised that there may be conflicts of interest (professional and political) between anthropologists, particularly between visiting and local researchers, and especially when cross-national research is involved:
a) Consideration for and consultation with anthropologists who have already worked or are currently working in the proposed research setting is advisable and is also a professional courtesy. In particular, the vulnerability of long-term research projects to academic intrusion should be recognised;
b) In cross-national research, consideration should be given to the interests of local scholars and researchers, to the problems that may result from matters such as the disparities in resources available to visiting researchers, and to problems of equity in collaboration. As far as is possible and practicable, visiting anthropologists should try and involve local anthropologists and scholars in their research activities but should be alert to the potential for harm that such collaboration might entail in some contexts.
3) Sharing research materials: Anthropologists should give consideration to ways in which research data and findings can be shared with colleagues and with research participants. However in certain instances this can prove to be difficult where political leaders, invading armies, military, multi-national corporations and the state are being criticised on various matters of injustice.
a) Research findings, publications and, where feasible, data should be made available in the country where the research took place. If necessary, it should be translated into the national or local language. Researchers should be alert, though, to the harm to research participants, collaborators and local colleagues that might arise from total or even partial disclosure of raw or processed data or from revelations of their involvement in the research project. Anthropologists should weigh up the intended and potential uses of their work and the impact of its distribution in determining whether limited availability of results is warranted and ethical in any given instance.
b) Where the sharing with colleagues of raw, or even processed data or their (voluntary or obligatory) deposition in data archives or libraries is envisaged, care should be taken not to breach privacy and guarantees of confidentiality and anonymity, and appropriate safeguards should be devised.
4) Collaborative and team research: In some cases anthropologists will need to collaborate with researchers in other disciplines, as well as with research and field assistants, clerical staff, students etc. In such cases they should make clear their own ethical and professional obligations and similarly take account of the ethical principles of their collaborators. Care ASA Ethical Guidelines 2011 www.theasa.org 9 should be taken to clarify roles, rights and obligations of team members in relation to matters such as the division of labour, responsibilities, access to and rights in data and fieldnotes, publication, co-authorship, professional liability, etc.
5) Responsibilities towards research students and field assistants: Academic supervisors and project directors should ensure that students and assistants are aware of the ethical guidelines and should discuss with them potential (as well as actual) problems which may arise during the stages/periods of fieldwork or writing-up. Teachers/mentors should publicly acknowledge student/trainee assistance in research and preparation of their work; give appropriate credit for co-authorship to students/trainees; encourage publication of worthy student/trainee papers; and compensate students/trainees justly for their participation in all professional activities. It should also be a duty to acknowledge the support and intellectual input of colleagues in the field.
IV. Relations with own and host governments
Anthropologists should be honest and candid in their relations with their own and host governments.
1) Conditions of access: Researchers should seek assurance that they will not be required to compromise their professional and scholarly responsibilities as a condition of being granted research access.
2) Cross-national research: Research conducted outside one's own country raises special ethical and political issues relating to personal and national disparities in wealth, power, the legal status of the researcher, political interest and his or her national political systems:
a) Anthropologists should bear in mind the differences between the civil and legal, and often the financial position of national and foreign researchers and scholars;
b) They should be aware that irresponsible actions by a researcher or research team may jeopardise access to a research setting or even to a whole country for other researchers, both anthropologist and non-anthropologist. Being cognisant of the consequence of one's research activities is particularly relevant when anthropologists consulting for governments, multi-national corporations, invading armies and the military do not prioritise the rights and interests of the local population and in cases where the ostensible aims of the intervention might reasonably be questioned by critical and reflective social scientists.
3) Open research: Anthropologists owe a responsibility to their colleagues around the world and to the discipline as a whole not to use their anthropological role as a cover for clandestine research or activities.
4) Legal and administrative constraints: Anthropologists should note that there may be a number of national laws or administrative regulations which may affect the conduct of their research, matters pertaining to data dissemination and storage, publication and rights of research subjects, sponsors and employers, etc They should also remember that, save in a very few exceptional circumstances, social research data are not privileged under law and may be subject to legal subpoena. Such laws vary by jurisdiction. Some which may have consequences for research and publication in the U.K. are, for example, the Data Protection Act, law of confidence, Race Relations Act, defamation laws, copyright law, law of contract, and the Official Secrets Act.
V. Responsibilities to the wider society
Anthropologists also have responsibilities towards other members of the public and wider society. They depend upon the confidence of the public and they should in their work attempt to promote and preserve such confidence without exaggerating the accuracy or explanatory power of their findings.
1) Widening the scope of social research: Anthropologists should use the possibilities open to them to extend the scope of social inquiry and to communicate their findings for the benefit of the widest possible community. Anthropologists are most likely to avoid restrictions being placed on their work when they are able to stipulate in advance the issues over which they should maintain control; the greatest problems seem to emerge when such issues remain unresolved until the data are collected or the findings emerge.
2) Considering conflicting interests: Social inquiry is predicated on the belief that greater access to well-founded information will serve rather than threaten the interests of society/ies:
a) Nonetheless, in planning all phases of an inquiry, from design to presentation of findings, anthropologists should also consider the likely consequences for the wider society, groups within it, and possible future research, as well as for members of the research population not directly involved in the study as well as the immediate research participants;
b) That information can be misconstrued or misused is not in itself a convincing argument against its collection and dissemination. All information is subject to misuse and no information is devoid of possible harm to one interest or another. Individuals may be harmed by their participation in social inquiries, or group interests may be harmed by certain findings. Researchers are usually not in a position to prevent action based on their findings; but they should, attempt to pre-empt likely misinterpretations and to counteract them when they occur.
3) Maintaining professional and scholarly integrity: Research can never be entirely objective - the selection of topics may reflect a bias in favour of certain cultural or personal values, the employment base of the researcher, the source of funding and any of these other factors may impose certain priorities, obligations and prohibitions. But anthropologists should strive for impartiality and fair representation and be open about known barriers to its achievement:
a) Anthropologists should not engage or collude in selecting methods designed to produce misleading results or in misrepresenting findings, either by commission or omission;
b) When it is likely that research findings will bear upon public policy and opinion anthropologists should be careful to state any significant limitations on their findings and interpretations.
The reputation of anthropological research will inevitably depend less on what professional bodies assert about their ethical norms than on the conduct of individual researchers. We recognise that ethical views and conclusions may legitimately differ, even when there is agreement about the facts of the case. The researcher thereby needs to reflect on their own position in the research and their research practices at all stages. These guidelines are aimed at helping anthropologists to reach an equitable and satisfactory resolution of their (potential) dilemmas. This statement of ideals does not impose a rigid set of rules backed by institutional sanctions, given the variations in both individuals' moral precepts and the conditions under which they work. Guidelines cannot resolve difficulties in a vacuum nor allocate greater priority to one of the principles than another. Instead, they are aimed at educating anthropologists, sensitizing them to the potential sources of ethical conflict and dilemmas that may arise in research, scholarship and professional practice, and at being informative and descriptive rather than authoritarian or prescriptive. They aim to ensure that where a departure from the principles is contemplated or where the privileging of one group or interested party or parties is deemed situationally or legally necessary, the researcher's decisions should be based on foresight and informed deliberation.
Just as the current document has been immeasurably enriched by comments and contributions from ASA members, we very much hope that ASA membership will continue to call attention to issues and resources relating to the ethical guidelines of anthropology for the purpose of debate and deliberation.
The amendments to the ASA Ethics Guidelines were drafted by the ASA Executive Committee Members during the period July 2010 – November 2011. The Committee members were James Fairhead, Raminder Kaur, Nayanika Mookherjee, James Staples, Catherine Degnen and Garry Marvin. The ASA Ethics Guidelines were last updated in 1999 and on receiving considerable feedback from the ASA members the need was felt to update and amend the Guidelines in the light of the changing disciplinary nature of anthropology. The first version of this draft amended Guidelines were sent to all ASA Members in February 2011. A large number of ASA members responded with comments and thanks to all for contributing to this process. At the ASA AGM held on 4th March 2011 it was decided that the recent amendments would be incorporated into the Ethics Guidelines and this second version of the draft guidelines will be finalised in due course in June 2011. Thereafter that version of the document was sent out to all ASA members for a final consultation process and all subsequent responses were received by end of July 2011 for them to be incorporated into the document. This version of the ASA Ethics Guidelines was proposed at an extraordinary AGM at the ASA 2011 conference in Lampeter, Wales on 15th September 2011. On 12th October 2011, the Executive committee approved this version of the Ethics Guidelines. The Committee considered all comments from the membership in formulating the final draft in October 2011. The Committee also gratefully acknowledges the use of some language from the codes of ethics of the American Anthropological Association. We hope to publish this version of the Ethics Guidelines on the ASA web site (http://www.theasa.org). Members are urged to bring to the attention of the ASA ethics officer (ethics(at)asa.org) any amendments that they would like to make to the ethics guidelines and suggested amendments can be added annually to the Guidelines as Addenda, on approval at the ASA AGM.
Sample Code of Research Ethics
as adapted by the Alaska Native Science Commission from
the Kahnawake Schools Diabetes Prevention Project
Copyright 459302 (January 22, 1997)
The [Name of Project] is a partnership of the people of the [Name of Community] and researchers of [Name of Research Organization]. In this document these groups are referred to as the Partners.
The community is represented by the [Name(s) of Community Organization and Community Researchers] and the researchers by the [Name(s) of Researchers].
The partners will work cooperatively and collaboratively in the design, implementation, analysis, interpretation, conclusion, reporting and publication of the experiences of the project. Each partner provides ideas and resources that come from the experience, knowledge and capability of all its members. Together, through respect for each other, consultation, and collaboration, they significantly strengthen the project and its outcomes. All partners of the project share an understanding that community based research is a powerful tool for learning about the community while contributing to the community in which it is being conducted.
Collaborative research acknowledges that there must be respect for the scientific and social integrity of the project. Each group has obligations towards the other partners.
PURPOSE OF THE CODE OF ETHICS:
The purpose of this code of ethics is to establish a set of principles and procedures to guide the partners to achieve the goals and objectives of the project. The code outlines the obligations of each of the partners through all of the phases of the project, from the design of the research through to the publication and communication of the experiences of the project.
The sovereignty of the community to make decisions about research in the community is recognized and respected. The researchers should maximize the benefits to the community as a whole and to individual community volunteers. Research should empower the community to support community goals of health and wellness, to improve its conditions and to fulfill its traditional responsibility of caring for the generations to come.
- The community must be involved as a full partner in all aspects of the research. Continuous consultation and collaboration should characterize the partnership.
- The strengths and culture of the community, including community researchers and staff as well as material resources, must be respected and utilized whenever possible.
- Written permission must be obtained from the partners before beginning the research projects.
- Permission from all individuals participating must be obtained prior to collecting personal information.
- The confidentiality of all individuals must be respected. If necessary, the community involved may choose to remain anonymous when reporting the results.
- All research results, analyses and interpretations must first be reviewed by the partners to ensure accuracy and avoid misunderstanding.
- All data collected belongs to the community and must be returned to the community.
- The partners must all be involved in making decisions about the publication and the distribution of all or parts of the research results.
- The community must agree to the release of information.
OBLIGATIONS OF THE PARTNERS OBLIGATIONS OF THE RESEARCHERS:
- To do no harm to the community.
- To involve the community in active participation rather than passive acceptance.
- To ensure the design, implementation, analysis, interpretation, reporting, publication and distribution of the research are culturally relevant to the community and in agreement with the standards of competent research.
- To undertake research that will contribute something of value to the community in which the research is being conducted. To impart new skills to community members.
- To help to address any issues that are raised as a result of research.
- To provide expertise to scientifically answer questions that emerge from the community.
- To promote academic diffusion of knowledge through written publications and oral presentations. This includes the documentation of the undertaking of the project and of the results.
- To be guardians of the data until the end of the project and to return that data to the community at the end of the project. To be involved in any future analysis of the data after the data has been returned to the community.
OBLIGATIONS OF THE COMMUNITY RESEARCHERS:
Community researchers are regarded as the Project Staff and those Co-investigators who are employed within the community. In addition to the obligations listed for researchers, the community researcher is obligated:
- To maintain a long-term relationship of trust in the dual role of caregiver, educator, and researcher: this will only be possible if the needs of the community are always considered as the first priority in any decision.
- To communicate with researchers during all phases of the research.
- To arrange for researchers to meet with the partner Committees and/or Board of Directors, and any other local organizations to implement and promote the project.
- To facilitate supervisory meetings of the Intervention and Evaluation teams.
- To participate in all phases of the project, review all research results, analyses and interpretations for accuracy and present information to the community.
OBLIGATIONS OF THE COMMUNITY PARTNER:
- To represent the community through their respective organizations.
- To be updated by the Project Staff on a determined basis to support the development and offer analysis of the activities to ensure compatibility with the project goal and objectives.
- To meet with the Project Co-investigators to maintain awareness and to offer recommendations concerning the research aspect of the project.
- To communicate with representatives of other communities to share ideas and program development for benefit and involvement.
- To serve as the guardian of all evaluation data after the completion of the project.
- To receive all requests for the use of the data by other researchers after the completion of the project.
- To approve of or write a disagreement to the interpretation of the data analysis.
The purpose of the project is to investigate the research questions described in the protocol. Since this project is unique, the results will be of interest to many other communities. For this reason it is necessary to share the experience of the project with the largest audience who might benefit from it. Part of the research process includes the communication of research results to other people and organizations in similar areas of research.
Communications will be directed at four general audiences:
- Health, Education and other officials
- Scientists and Researchers
- The Community Council or governing body
- The community, at large.
Health, education and other officials are those people providing services or working on programming and planning. They will be interested in how the project was developed and implemented as well as the outcome of project efforts. Scientists and researchers will be interested in the methods used, the process of the program, the impacts measured, and the answers provided to the research questions. The community at large is everyone who participated in the project as well as those who are generally interested in the project goals.
All aspects of the project can be considered as worthy of communication. All communication pertaining to the project will follow generally accepted ethical standards. The principles include:
- Anonymity: Results to be presented in a grouped, not individual manner.
- Confidentiality: All personal information provided by individuals will be made anonymous whenever possible and remain confidential unless otherwise determined by the individuals.
- Priority of Communities Involved: The communities participating will be the first to review and receive results and the first invited to provide input and feedback on the results.
- Respect: Consideration for the communities and all participants must be observed in all communications.
Results from research projects usually are presented in the following ways:
- Articles in scientific journals, referred to as "a paper".
- Oral presentation of "a paper" at a scientific conference or meeting.
- Oral presentation to the community at large.
- Written document to the community at large.
- Teaching examples.
For scientific journals and oral presentations at scientific conferences and meetings there is a standard process involved. It is therefore possible to outline the steps from idea to final communication and outline the responsibilities for those involved with the authorship. However, these points should also apply to communications to the community. From here on the word communication will be used to describe both oral presentations and written papers.
It will be the responsibility of the project partners to ensure that the staff and investigators who have made significant contribution to the project can qualify for authorship. These are people who have worked directly on the project. However, being involved only in data collection or delivery of a program will not be sufficient for authorship.
- The Idea: All ideas for communications must be presented to the partners before writing begins.
- Preparing the Communication: The first author of an article (i.e. the person whose name appears first on the article) will assume the major responsibility for preparing the article. The first author will assume most of the writing responsibility. Other authors contributing to the communication will appear in descending order. This order will depend on the contribution made to the subject of the communication and the preparation and writing of the communication, including hunters and elders, in the body of the document and the author's section.
- Submitting a Communication: All authors on the paper must approve of the final version before the paper is submitted to the journal, conference, etc. Furthermore, final versions of all papers must be approved by the partners before submission.
- Peer Review: Communications may be reviewed by scientific and community people considered knowledgeable in the subject of the communication. This peer review process may result in suggested changes of the communication in order for publishing the article in the journal of interest. All the authors of the communication must approve any changes made in the review. This will be done by a letter to the editor signed by all the authors.
- This next section deals with special communications.
- Abstracts: An abstract is a short summary of the content of a communication. When someone wants to present a paper at a conference, an abstract will be sent to the conference organizers. The abstract will then be used to decide if the communication will be accepted for presentation. In case of a late call for an abstract, the partners should be contacted as soon as possible. If there are no objections, the abstract should be sent immediately. The preparation of the communication will proceed following the steps outlined previously.
- Responsibility of Communication by the Partners: It is part of the shared responsibility of the partners to prepare communications for the community and the scientific community. Those who have more of an interest in them would appropriately prepare communications for the community: likewise for communication to the scientific communication. This should not limit the authors to one or the other.
CODIFICATION, DATA ENTRY AND DATA CLEANING
- The activities organized by the project should ensure that the data collection process is in accord with the host community values and norms, and competent scientific practice.
- Participation in the evaluation activities is voluntary for the people in both communities. The people who express the desire to withdraw will be able to do so at any time.
- All information or data collected on individuals will be kept strictly confidential. An identification number will be given and the names of participants will be removed. A file containing names and identification numbers will be kept for future follow-up. Only the Project Coordinator will have access to this file.
- For reasons of confidentiality, the person responsible for coding the collected information should not have access to the names of the participants. The names of the participants should be removed prior to data coding.
- The coordinator is responsible for the quality control of the data coding and entry.
PROCESS FOR APPLICATION TO RESEARCH IN CONJUNCTION WITH THE PROJECT:
The researcher and community need to meet for the purpose of discussion and approval of the research idea and the protocol involved. To meet this end, the following steps will be followed to make application:
- A letter is sent to one of the partners to request a meeting to discuss the research proposal. This letter is to include a summary description of the proposed research, a time frame for research, reporting, and the expected conclusion.
- The recipient of the request is responsible to: distribute the material to the other partners within one working week of receipt of the letter, establish a meeting with the partners and the researcher, and send a copy of the Code of Research Ethics to the applicant to allow for preparation.
- If there are no objections from any of the members of the partners to the research proposal, formal written consent is to be sent within thirty (30) days of the meeting. In the event of any objections, a second meeting with the proposed researcher is to be held within two working weeks for discussion on the objection.
- The researcher must agree to comply with all aspects of the project Code of Research Ethics. The proposal will be rejected if the researcher refuses to comply with any aspect.
- All partners will review and discuss the completed research document(s) before publication. This review is to take place thirty (30) days following receipt of the research document(s).
- If there is any dissent, the dissenter is responsible to write and present a written response at this meeting. The dissent is to be included with the submission of the research document(s)
NAPA Ethical Guidelines for Practitioners
The preparation of the ethics statement involved a unique partnership between the National Association for the Practice of Anthropology (NAPA) and the Southern California Applied Anthropology Network (SCAAN). Jean Gilbert, a SCAAN member and Chair of the NAPA Ethics Committee, worked with a local committee composed of several of her fellow SCAAN members (Claudia Fishman, Neil Tashima and Barbara Pillsbury) to create the first draft, which appeared in the December 1987 Anthropology Newsletter, pp 7-8. Membership comments were solicited at that time. The Guidelines were also sent to all of the local practitioner organizations (LPOs) for comment, and in addition were the topic of discussion in a regular SCAAN monthly meeting. The final version of the NAPA Ethical Guidelines for Practitioners was published in the November 1988 Anthropology Newsletter, pp 8-9. Gilbert thanked the membership of SCAAN and the following individuals who reviewed and commented on the draft: Fred Hess, Elvin Hatch, Barbara Frankel and Gene Anderson. The final version incorporated many of their comments.
NAPA Ethical Guidelines for Practitioners
These guidelines have been developed by the National Association for the Practice of Anthropology as a guide to the professional and ethical responsibilities that practicing anthropologists should uphold. A practicing anthropologist is a professionally trained anthropologist who is employed or retained to apply his or her specialized knowledge problem solving related to human welfare and human activities. The designation “practicing anthropologist” includes full-time practitioners who work for clients such as social service organizations, government agencies and business and industrial firms. This term also includes part-time practitioners, usually academically based anthropologists, who accept occasional assignments with such clients. The substantive work of practicing anthropologists may include applied research, program design and implementation, client advocacy and advisory roles and activities related to the communication of anthropological perspectives. These guidelines are provided with the recognition that practicing anthropologists are involved in many types of policy-related research, frequently affecting individuals and groups with diverse and sometimes conflicting interests. No code or set of guidelines can anticipate unique circumstances or direct practitioner actions in specific situations. The individual practitioner must be willing to make carefully considered ethical choices and be prepared to make clear the assumptions, facts and issues on which those choices are based. These guidelines therefore address general contexts, priorities and relationships which should be considered in ethical decision making in anthropological practice.
1. Our primary responsibility is to respect and consider the welfare and human rights of all categories of people affected by decisions, programs or research in which we take part. However, we recognize that many research and practice settings involve conflicts between benefits accruing to different parties affected by our research. It is our ethical responsibility, to the extent feasible, to bring to bear on decision making, our own or that of others, information concerning the actual or potential impacts of such activities on all whom they might affect. It is also our responsibility to assure, to the extent possible, that the views of groups so affected are made clear and given full and serious consideration by decision makers and planners, in order to preserve options and choices for affected groups.
2. To our resource persons or research subjects we owe full and timely disclosure of the objectives, methods and sponsorship of our activities. We should recognize the rights of resource persons, whether individuals or groups, to receive recognition for their contributions or to remain anonymous if they so desire or to decline participation altogether. These persons should be informed of our commitment to the principle of confidentiality throughout the design of research or other activities involving resource persons and should thoroughly investigate and understand all of the limitations on our claims of confidentiality and disclosure.
3. To our employers we owe competent, efficient, fully professional skills and techniques, timely performance of our work and communication of our findings and recommendations in understandable, non-jargonistic language.
As practicing anthropologists, we are frequently involved with employers or clients in legally contracted arrangements. It is our responsibility to carefully review contracts prior to signing and be willing to execute the terms and conditions stipulated in the contract once it has been signed.
At the outset of a relationship or contract with an employer or client, we have an obligation to determine whether or not the work we are requested to perform is consistent with our commitment to deal fairly with the rights and welfare of persons affected by our work, recognizing that different constituencies may be affected in different ways. At this time, we should also discuss with our employer or client the intended use of the data or materials to be generated by our work and clarify the extent to which information developed during our activities can be made available to the public. Issues surrounding the protection of subject confidentiality and disclosure of information or findings should be thoroughly reviewed with the potential employer or client. We will not undertake activities which compromise our ethical responsibilities.
We will carry out our work in such a manner that the employer fully understands our ethical priorities, commitments and responsibilities. When, at any time during the course of work performance, the demands of the employer require or appear to require us to violate the ethical standards of our profession, we have the responsibility to clarify the nature of the conflict between the request and our standards and to propose alternatives that are consistent with our standards. If such a conflict cannot be resolved, we should terminate the relationship.
4. In our relations with students and trainees, we will be candid, fair, nonexploitative, nondiscriminatory and committed to the student’s or trainee’s welfare. We recognize that such mentoring does involve an exchange in which practitioners share their knowledge and experience in return for the significant effort and contribution of the students/trainees. We should be honest and thorough in our presentation of material and should strive to improve our teaching and training techniques and our methods of evaluating the effectiveness of our instruction.
As practicing anthropologists we are frequently called upon to instruct, train or teach individuals, anthropologists and others in nonacademic settings (workshop participants, in-service trainees, continuation or certification program trainees and research teams). To such persons, we owe training that is informed, timely and relevant to their needs.
Our instruction should inform both students and trainees of the ethical responsibilities involved in the collection and use of data. To our students and trainees we owe respect for and openness to nonanthropological methods and perspectives. Student and trainee contributions to our work, including publications, should be accurately and completely attributed.
5. To our colleagues, anthropologists and others, we have a responsibility to conduct our work in a manner that facilitates their activities or that does not unjustly compromise their ability to carry out professional work.
The cross-disciplinary nature of the work of practicing anthropologists requires us to be informed and respectful of the disciplinary and professional perspectives, methodologies and ethical requirements of nonanthropological colleagues with whom we work.
We will accurately report the contribution of our colleagues to our research, practice-related activities and publications.
6. To the discipline of anthropology we have a responsibility to act in a manner that presents the discipline to the public and to other professional colleagues in a favorable light. We will point out the value of anthropological contributions to the understanding of human problems and humankind. Where appropriate in the context of our work, we will encourage the use of anthropological approaches and recommend the participation of other anthropologists.
We will contribute to the growth of our discipline through communicating and publishing scientific and practical information about the work in which we are engaged, including, as appropriate, theory, processes, outcomes and professional techniques and methods.