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Business Ethics Awareness

The University will foster and promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.  To that end, the University has created a “Business Ethics and Awareness Compliance Program (BEaCoP)” that incorporates elements of existing Policies and Procedures in order to observe sound business practices and execute principles of responsible stewardship expected by our Board of Trustees, collaborative partners and external sponsors.

 The Stevens’ Business Ethics and Awareness and Compliance Program (BEaCoP, the “Program”)

The BEaCoP shall consist of the “Program” and the “Program’s” Internal Control System.  Integral elements of each are as follows:

  • The “Program”
    • Training and education required of all University employees for targeted areas of focus such as COI, Business Ethics and Compliance and others
    • Other training and education available to the entire University community in profession-specific areas, as identified
    • All subcontractors receiving over $5,000,000, will be required to certify to the existence of training and education programs provided to their affected employees
  • The Internal Control System
  • Responsibility and oversight for the University’s BEaCoP resides in the Chief Risk and Compliance Officer.  Assisting this principal in the management and maintenance of the University’s BEaCoP will be the Asst. Director of Research Compliance and Export Control in the Office of Sponsored Research 
  • The University will perform an annual review of all contracts signed and executed by the BEaCoP principal in order to ensure that no conduct in conflict with the BEaCoP has occurred. 
  • The University’s BEaCoP and all university Policies and Procedures that are incorporated as part of the BEaCoP will be scheduled for annual review for continued relevance and applicability.  Amendments will be made as necessary and all amended practices will be incorporated into the training and education provided to the campus community
    • Internal audits of affected business functions and user groups will be performed according to the schedule approved by the University’s Audit Committee
    • Annual training will be required for identified user groups with an established pass/fail requirement embedded in the training
    • Periodic assessment of the risk of criminal conduct
    • A university Fraud and Abuse Hot Line provides anonymous reporting opportunity to campus
    • Disciplinary action in accordance with the procedures described in the University “Code of Ethics” and “Financial Irregularities” shall be exercised for improper conduct or failure to take reasonable steps to prevent or report detected improper conduct.  Additionally, faculty found to have engaged in improper conduct shall undergo review by the Professional Practices Committee 
    • The University shall report all violations of federal criminal law involving fraud, conflict of interest, bribery or gratuity violations
    • University shall include the substance of FAR 52.203-13 in all subcontracts that have a value in excess of $5,000,000 and a performance period of more than 120 days

 

Related University Policies

The following Policies are incorporated into the University’s “Business Ethics Awareness and Compliance Program:”