Principles of Responsible Conduct
For a PDF of this document which will be updated, as necessary, with the most up-to-date links, click on the Principles of Responsible Conduct link on the Office of Audit, Compliance and Privacy website. |
Introduction
The mission of the University of Pennsylvania and its Health System is to offer a world class education to our students, train future leaders of our country, expand and advance research and knowledge, serve our community and society both at home and abroad, and provide the most expert and outstanding health care for our patients. In pursuing this mission, and to ensure the continued excellence of the University and its reputation, all members of the University community need to understand and uphold both legal requirements and the highest of ethical standards.
In the following Principles of Responsible Conduct, we articulate the basic expectations that should guide each of us in our work at Penn. These Principles are embedded within many policies and practices identified throughout University and Health System handbooks, manuals, websites and other materials. We have endeavored to distill these policies, rules, and guidelines for easy review and access. The Principles are not intended to be a comprehensive catalogue of all applicable rules and policies of the University and the Health System. Rather, these Principles set forth the underlying expectations that we have for the conduct of University and Health System activities with the highest standards of integrity and ethics. Useful sites to relevant policies and resources are included.
We urge you to read these Principles closely and familiarize yourself with both the expectations and the resources provided.
Amy Gutmann, President
Ron Daniels, Provost
Craig Carnaroli, Executive Vice President
Arthur Rubenstein, Executive Vice President for the Health System
As reflected in the policies that are identified below, Penn has many policies that govern the behavior of all Penn faculty, administration and staff. The ethical expectations contained in these policies are highlighted in the text of the ten principles that follow.
1. Ethical and Responsible Conduct.Penn’s faculty, administration and staff should conduct themselves ethically, with the highest integrity, in compliance with all applicable laws, regulations, and University policies, in all aspects of their work. They should be fair and principled in University and Health System business transactions and other related professional activities, acting in good faith when dealing with both internal constituents and external entities. Their conduct should always reflect their positions of trust and loyalty with respect to the University, the Health System, and members of these communities.
Policies, Statements and Guidelines:
Stewardship Statement–Office of Audit, Compliance and Privacy:
http://www.upenn.edu/audit/OACP/Compliance/
compliance_stewardship_statement.htm
Statement of Faculty Responsibility:
http://www.upenn.edu/assoc-provost/handbook/ii_e_1.html
Adherence to University Policy:
http://www.hr.upenn.edu/policy/policies/001.asp
University of Pennsylvania Medical Center Policy Organizational Ethics:
http://uphsxnet.uphs.upenn.edu/hupadmpl/1_12_10a.pdf
Pennsylvania Hospital Policy Code of Ethical Behavior:
http://uphsxnet.uphs.upenn.edu/pahhome/pahpolicies/RE5.pdf
2. Respect for Others in the Workplace. Penn recognizes that people are the most important resource for achieving eminence in accomplishing our mission in the areas of teaching, research, community service, and patient care. Penn is an institution that values academic freedom, diversity and respect for one another. Penn is committed to the principle of non-discrimination and does not tolerate conduct that constitutes harassment on any basis, including sexual, racial, ethnic, religious, or gender harassment.
Policies, Statements and Guidelines:
Academic Freedom:
http://www.upenn.edu/assoc-provost/handbook/ii_a.html
Diversity:
http://www.upenn.edu/affirm-action/
Sexual Harassment and Sexual Assault:
Sexual Harassment Policy
https://almanac.upenn.edu/archive/volumes/v51/n24/OR-shp.html
Acquaintance Rape and Sexual Violence Policy No. 715
http://www.upenn.edu/affirm-action/docs/oaaph.pdf
Consensual Sexual Relations Between Faculty and Students
http://www.upenn.edu/assoc-provost/handbook/vi_e.html
Sexual Harassment Guidance
http://www.upenn.edu/affirm-action/shhandbook.html
Workplace Violence:
https://almanac.upenn.edu/archive/v50/n32/OR-vio.html
Drug Free Workplace:
http://www.hr.upenn.edu/policy/policies/705.asp
http://www.upenn.edu/assoc-provost/handbook/vi_f.html
http://www.upenn.edu/assoc-provost/handbook/vi_g.html
University of Pennsylvania Medical Center Policy:
http://uphsxnet.uphs.upenn.edu/huphrpl/hr_pdfs/
Sexual%20Harrassment%202-05-15.pdf
Pennsylvania Hospital Policy:
http://uphsxnet.uphs.upenn.edu/pahhome/pahpolicies/HR60.pdf
University of Pennsylvania Medical Center (HUP/CPUP) Policy Non-Discrimination:
http://uphsxnet.uphs.upenn.edu/hupadmpl/1_12_17.pdf
Equal Opportunity/Affirmative Action: University of Pennsylvania Medical Center Policy Statement
http://uphsxnet.uphs.upenn.edu/huphrpl/hr_pdfs/POLICY STATEMENT ON EQUAL OPPORTUNITY.pdf
Pennsylvania Hospital Policy:
http://uphsxnet.uphs.upenn.edu/pahhome/pahpolicies/HR2.pdf
University of Pennsylvania Medical Center Staff Rights Policy:
http://uphsxnet.uphs.upenn.edu/huphrpl/hr_pdfs/Staff%20
Rights%202-05-21.pdf
3. Avoidance of Conflict of Interest. As more fully stated in Penn’s conflict of interest policies, Penn’s faculty, administration and staff should avoid conflicts of interest in work at Penn. As a non-profit institution, it is imperative, for both legal and ethical reasons, that University and Health System employees do not improperly benefit from their positions of trust at Penn. Financial conflicts must be appropriately disclosed in accordance with conflict of interest and conflict of commitment policies, so that they can be reviewed, and as appropriate, managed or eliminated. Faculty, administrators and staff are responsible for identifying potential conflicts and seeking appropriate guidance.
Policies, Statements and Guidelines:
Conflict of Interest General Website:
http://www.upenn.edu/research/rcr/conflict.htm
Conflict of Interest–Trustees: Conflict of Interest Policy June 2000
http://www.upenn.edu/research/CoiTrusteesResolution.pdf
Conflict of Interest–Faculty:
http://www.hr.upenn.edu/policy/policies/005.asp
Conflict of Interest–Staff:
http://www.hr.upenn.edu/policy/policies/005.asp
Guidelines for Extramural Activities:
http://www.hr.upenn.edu/policy/policies/006.asp
Policy Related to Copyright and Commitment of Effort:
http://www.upenn.edu/assoc-provost/handbook/v_e.html
University of Pennsylvania Health System Guidelines for
Extramural Activity of Faculty of Medical Center and Health System:
http://www.med.upenn.edu/facaffrs/Policies/
Extramural_Guidelines.pdf
Guidelines for Institutional Conflicts of Interest for the Leadership and Senior Administration of the Health System:
http://www.med.upenn.edu/facaffrs/Policies/Conflict_of_
Interest_Guidelines.pdf
4. Responsible Conduct in Research.As members of a complex research university, Penn faculty, administrators and staff have significant responsibility to ensure that research is conducted with the highest integrity, and in compliance with federal, state, and local laws and regulations, as well as University and Health System policy.
Policies, Statements and Guidelines:
University Policies and Procedures Relating to Research:
http://medley.isc-seo.upenn.edu/penn_portal/research.php
http://www.upenn.edu/assoc-provost/handbook/iii_a.html
Services for Researchers:
http://www.upenn.edu/research/DetailedPolicies.htm#COI
Responsible Conduct for Research:
http://www.upenn.edu/assoc-provost/handbook/iii_c.html
Penn Manual for Clinical Research:
http://www.med.upenn.edu/pennmanual/index.html
Patent Policy:
https://almanac.upenn.edu/archive/issues/past/pdf_files/OR-patent-adobe.pdf
UPHS Compliance Program:
http://uphsxnet.uphs.upenn.edu/billcomp/compliance/index.html
Guidelines for Student Protection in Sponsored Research Projects:
http://www.upenn.edu/assoc-provost/handbook/iii_e.html
Vice Provost for Research:
http://medley.isc-seo.upenn.edu/penn_portal/research.php
5. Responsible Stewardship and Use of Penn Property, Funds, and Technology.Penn faculty, administration and staff are expected to ensure that Penn property, funds and technology are used appropriately to benefit the institution, consistent with all legal requirements as well as University and Health System policies.
Policies, Statements and Guidelines:
Socially Responsible Purchasing:
http://www.purchasing.upenn.edu/social
Purchasing Overview for Newly Appointed Faculty and Staff:
http://www.purchasing.upenn.edu/buyinfo/overview.php
Use of University Resources:
http://www.hr.upenn.edu/policy/policies/003.asp
Safeguarding University Assets:
http://www.hr.upenn.edu/policy/policies/002.asp
Policy on Acceptable Use of Electronic Resources:
http://www.upenn.edu/computing/policy/aup.html
Purchasing (ProCard) and Fleet Fuel Card Program:
http://www.purchasing.upenn.edu/buytools/card.php
Fraud:
http://www.hr.upenn.edu/policy/policies/007.asp
Guidelines for Extramural Activities, Associations, & Interest for Staff:
http://www.hr.upenn.edu/policy/policies/006.asp
Employment of Members of the Same Family:
http://www.hr.upenn.edu/policy/policies/110.asp
Nepotism—University of Pennsylvania Medical Center Policy:
http://uphsxnet.uphs.upenn.edu/huphrpl/hr_pdfs/Nepotism%202-01-08.pdf
Pennsylvania Hospital Policy:
http://uphsxnet.uphs.upenn.edu/pahhome/pahpolicies/HR18.pdf
Dual Employment—Hospital of the University of Pennsylvania Policy:
http://uphsxnet.uphs.upenn.edu/huphrpl/hr_pdfs/
Dual%20Employment%202-01-11.pdf
6. Environmental Health and Safety. Penn is committed to the protection of the health and safety of the university community and the creation of a safe working environment. To accomplish this end, Penn provides training in health and safety regulation and policy and Penn faculty, administration, and staff are expected to comply with sound practices and legal requirements.
Policies, Statements and Guidelines:
Penn’s Environmental Health and Safety Committee—Charge:
http://www.ehrs.upenn.edu/ehsc
7. Respect for Privacy and Confidentiality. In their various roles and positions at Penn, faculty, administration and staff become aware of confidential information of many different types. Such information may relate to students, employees, faculty, staff, alumni, donors, research sponsors, licensing partners, patients, and others. Penn faculty, administration and staff are expected to inform themselves about applicable legal, contractual, and policy obligations to maintain the confidentiality of such information, so as to protect it from improper disclosure, and to protect the privacy interests of members of our community.
Policies, Statements and Guidelines:
Privacy of Personal Information (Policy Related to Information):
http://www.upenn.edu/assoc-provost/handbook/v_a.html
Policy of Privacy in the Electronic Environment:
http://www.upenn.edu/assoc-provost/handbook/v_i.html
Confidentiality of Employee Records:
http://www.hr.upenn.edu/policy/policies/201.asp
Guidelines on the Confidentiality of Student Records:
http://www.upenn.edu/assoc-provost/handbook/iv_g.html
HUP Policies regarding HIPAA (Numbers H1-H20):
http://uphsxnet.uphs.upenn.edu/hupadmpl/1_12_H1.pdf
Pennsylvania Hospital Policies regarding HIPAA (Numbers hip1-hip21): http://uphsxnet.uphs.upenn.edu/pahhome/pahpolicies/hip1.pdf
University of Pennsylvania Health System/University of Pennsylvania School of Medicine Information Services Policy on Acceptable Use:
http://uphsxnet.uphs.upenn.edu/healthispl/pdf/is_acceptable.pdf
Confidentiality, Access to Information Security University of Pennsylvania Medical Center Policy:
http://uphsxnet.uphs.upenn.edu/hupadmpl/1_12_42.pdf
More information on privacy can be obtained at: http://www.upenn.edu/privacy
8. Appropriate Conduct with Respect to Gifts, Travel and Entertainment.Penn faculty, administration and staff are expected to conduct themselves so as to ensure that their positions are not misused for private gain, with respect to acceptance of gifts and the undertaking of university-related travel and entertainment.
Policies, Statements and Guidelines:
Gifts:
http://www.hr.upenn.edu/policy/policies/709.asp
Travel and Entertainment:
http://www.finance.upenn.edu/vpfinance/fpm/2350/2351.shtml
Acceptance of Gifts Grants, Contracts and Conditional Gifts:
http://www.upenn.edu/assoc-provost/handbook/vi_b.html
9. Appropriate Use of the University Name and Logos. Penn regulates the use of its name, its shield, and related trademarks and logos in order to protect the University’s reputation, and to ensure that their use is related to the University’s educational, research, community service, and patient care missions. Faculty, administration and staff are expected to protect the University name and logos from improper use.
Policies, Statements and Guidelines:
Use of the University’s Name:
http://www.upenn.edu/assoc-provost/handbook/vi_a.html
http://www.upenn.edu/secretary/nameuse.html
University of Pennsylvania Medical Center Policy on Faculty Use of Academic Titles & Institutional Stationery & Logos in Extramural Activity:
http://uphsxnet.uphs.upenn.edu/hupadmpl/1_12_09.pdf
10. Responsible Reporting of Suspected Violations and Institutional Response. Penn faculty, administration and staff are expected to report suspected material violations of University and Health System policies, as well as violations of applicable laws and regulations, to appropriate offices, as set forth in the various policies. Penn faculty, administration and staff may be subject to discipline in accordance with the policies.
Policies, Statements and Guidelines:
Termination and Separation Policies:
http://www.hr.upenn.edu/policy/termination.asp
Procedure Governing Sanctions Taken Against Members of the Faculty, Faculty Handbook II.R.16:
http://www.upenn.edu/assoc-provost/handbook/ii_e_16.html
Confidential Reporting and Help Line (1-888-BEN-TIPS):
http://www.upenn.edu/audit/oacp/compliance/
888_BEN_TIPS.htm
University of Pennsylvania/Health System Resource Offices
Reporting Line |
1-888-BEN-TIPS |
Audit, Compliance, and Privacy |
215-898-7260 |
Billing Compliance Information Line |
215-349-5423 |
Billing Compliance Reporting Line |
215-349-5422 |
Division of Business Services |
215-898-9155 |
Division of Public Safety |
215-898-7297 |
Environmental Health and Radiation Safety Office |
215-898-4453 |
Finance, Health System |
215-662-2992 |
Human Resources, Health System |
215-349-8418 |
Human Resources, University |
215-898-7281 |
Information Services, Health System |
215-662-7474 |
Information Systems and Computing, University |
215-898-1787 |
Human Resources, Learning & Education (University) |
215-898-3400 |
Office of Affirmative Action |
215-898-6993 |
Office of Comptroller, University |
215-898-7593 |
Office of the General Counsel |
215-746-5200 |
Office of Human Research |
215-746-7400 |
Office of Regulatory Affairs |
215-898-2614 |
Office of the Secretary |
215-898-7005 |
Office of the Treasurer |
215-898-1005 |
Ombudsman |
215-898-8261 |
Research Services |
215-898-7293 |
Risk Management |
215-898-4327 |
Tax |
215-898-6573 |
Almanac, Vol. 52, No. 26, March 21, 2006
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