Western Washington University

ETHICS IN WASHINGTON STATE HIGHER EDUCATION

AND WESTERN’S POLICIES AND FINANCES

New Employee Orientation

WWU Office of The Internal Auditor

Rev. 8-13-10

Presentation Objectives

Obtain an understanding of:

• The Office of the Internal Auditor,

• The Ethics In Public Service Act and related regulations,

• Other key state laws,

• University’s policy web site, and

• Common university financial terms and concepts

Office of the Internal Auditor

•Director, Matt Babick 650-3435•Senior Internal Auditor, Paul Schronen 650-4033•Assistant to Internal Audit and Assistant Attorney General, Suzanne Baker 650-3117

We are located in Old Main 330F. Our mail stop is 9015.

About the Office of the Internal Auditor

The Internal Audit Office is committed to assisting Western’s Board, management and staff in achieving their oversight, operating and management responsibilities through independent reviews designed to evaluate and promote the system of internal controls established by management.

To accomplish this, Internal Audit performs different types of services.

Types of Internal Audit Services

• Perform Audits (Operational, financial related, and compliance)

• Consultation Reviews• Special Investigations• Advice and Training

– We are available to answer questions in person, over the phone, e-mail or through the Contact the Internal Auditor web form on

our web site.

External Auditors

In addition to the university’s internal auditors, you may encounter external auditors on campus. The university has contracted with an external auditor to perform annual financial statement audits. Also, auditors from the State Auditor’s Office perform an accountability and compliance audit at Western every year.

Enough about auditors…

Ethics In Public Service Act

• All university employees, including student employees, are “state” employees.

• As such, we are responsible for complying with the Ethics In Public Service Act (Chapter 42.52 RCW).

• In general, the ethics law establishes minimum standards of conduct and provides guidance.

• State employees hold a public trust that obligate us to honesty and integrity in fulfilling our university responsibilities.

• We are obligated to conserve and protect state resources for the benefit of the public interest, not for private gain.

Ethics Training

Additional, in depth training is available at - • Human Resources Training web site (

http://www.wwu.edu/hr/od/training/descriptions.shtml#ethics )

• Executive Ethics Board web site (http://www.ethics.wa.gov/TRAINING/Training.htm )

(Also, you can contact Internal Audit for more information if you have specific ethics-related questions.)

State Ethics Board

• Ethics Board receives complaints and performs investigations of alleged ethics violations

• Ethics Board web site at http://ethics.wa.gov/ contains:

– Contact information– Frequently Asked Questions– Links to RCW and WAC– Training information– “Enforcement” page (list of violations & penalties)– Official Advisory Opinions– Newsletters and Brochures

Ethics Law Covers

The law covers a number of topics, including,• Appropriate use of resources• Conflicts of interest• Personal financial interests• Receiving gifts • Confidential Information• Compensation for outside activities• Receiving honoraria payments

Using University Resources

The part of the law that is most applicable to all state employees is using resources.

• The law defines how resources should and should not be used.

• You can always, of course, use university resources to perform university work.

What is a University Resource?

Resources include, but are not limited to: your state compensated time, university phones, fax machines, computers, printers, office space, e-mail system, internet access, and tools.

Personal Use – De Minimis Rules

• You are allowed to make personal use of resources as long as you follow the de minimis rules, and your use is not prohibited. (see subsequent slide)

• To be considered de minimis:– There must be little or no cost to the state,– The use is brief and occurs infrequently,– The use does not interfere with the performance of

any employee’s duties, and– The use does not compromise the security or

integrity of state property, information or software.

“Brief” and “Infrequent” Criteria

In a Frequently Asked Question published by the Executive Ethics Board, brief and infrequent means –

“…the use is no more than once a day and lasts a few minutes…”

More Restrictive State Rules for Motor Vehicle Use

The rules issued by the Office of Financial Management state that motor vehicles may only be used for “official state business…”, therefore no personal use is permitted.

Prohibited Uses of Resources

According to the Ethics law, the following uses

are expressly prohibited:– Conducting outside business or work,– Performing or facilitating illegal activities,– Campaigning or opposing/promoting a ballot issue– Taking any university property for personal use (even

if it is going to be thrown in the trash)– Supporting/promoting/soliciting for an outside

organization or group (except as noted on the next slide)

Supporting, Promoting or Soliciting for an Outside Organization or Group

• The Ethics law prohibits using university resources for supporting, promoting the interests of, or soliciting for an outside organization or group.

• The Ethics law does allow the use of university resources for supporting, promoting the interests of, or soliciting for an outside nonprofit organization IF it is allowed for in law or is authorized by the President or a Vice President.

Examples of Using Technology Resources

• Personal use of email – Yes*• Use computer for outside work - No• Occasional and limited use of internet – Yes*• Send a Happy Birthday email wish – Yes*• Include WWU e-mail address on outside work or

activity documents – No• Forward email jokes to other employees – No• Download games and programs - No (* Follow de minimis rules)

Using Resources For Outside Business or Work

• Outside Work: Is any activity performed by a university employee that is paid for by anyone other than Western Washington University, WWU Foundation or WWU Alumni.

• Using any university resources to perform work for your outside business or private employment is prohibited.

• Exception: Employees may follow the university’s Patent and Copyright policy.

Use of Resources for Political Purposes

Prohibited Activities:• Using work time to solicit signatures, raise funds,

or campaign for or against a candidate or ballot measure

• Using university facilities for political purposes, even after work hours

• Displaying political materials in or on university vehicles or facilities. EXCEPTION: The free speech issue of wearing campaign buttons or placing such materials in personal assigned spaces must be balanced with the obligation to not use visible public facilities to post such materials.

Conflicts of Interest• University employees may not have an

interest (financial or other) or engage in a business, transaction, professional activity, or incur an obligation that is in conflict with the proper discharge of the employee’s official duties at Western

• Conflicts of interest may be remedied by disclosure or abstaining from participating in a decision or action.

Receiving Honoraria Payments

• Occasionally, a university employee is offered an honorarium, which is any money or thing of value, for a speech, appearance, article or similar item in connection with their official role at Western.

• An honorarium can only be accepted if approved by the university and is not specifically prohibited by the Ethics law.

(http://apps.leg.wa.gov/RCW/default.aspx?cite=42.52.130)

Receiving Gifts

• Employees should not accept gifts or anything of value if it could be reasonably expected to influence your vote, judgment or action.

• Employees should generally not accept gifts in excess of $50 from a single source per year.

• If you can make purchasing decisions, the gifts that you can accept are limited to a specific list.

(Contact Internal Audit for more information if you have specific gift questions.)

Confidential Information

• University employees may not disclose confidential information gained during official duties or otherwise use confidential information for personal gain or benefit

• University employees must not intentionally conceal a record

that they know should be released

under the Public Disclosure Act

Now, a few other important laws that you should be aware of….

Public Records Act

• Washington law allows open public access to all state public records, except for those that are exempt from disclosure.

• University records relating to the conduct of university business are public records.

• University’s Public Records Officer (x2728) must be immediately notified of public record requests received by departments. The law requires that the Public Records Officer respond to requests within 5 working days of receipt of the request.

State Whistleblower Act

• This law encourages state employeesto report improper governmental actions to SAO.

• The State Auditor’s Office investigates the allegations and maintains confidentiality of the complainant.

• This law protects the complainant and others that participate in a Whistleblower investigation against retaliation or reprisal.

• Web site - https://www.sao.wa.gov/investigations/Pages/Whistleblower.aspx

State Whistleblower Act – Report Designees

Effective June 12, 2008, Western employees maymake Whistleblower reports to the followingUniversity report designees:

• Eileen Coughlin, Senior VP for Enrollment and Student Services

• Matt Babick, Internal Audit Director• Brent Carbajal, Provost and Vice President for Academic

Affairs • Rich Van Den Hul, Vice President For Business and Financial

Affairs• Chyerl Wolfe-Lee, Human Resources Director

Reporting Loss of Funds & Other Illegal Activities

• The university is required by law to report known or suspected loss of public funds or assets or

other illegal activities to the State Auditor’s Office.• Departments must retain documents and may not

enter into repayment agreements with employees.• Known or suspected violations of the Ethics In

Public Service Act must be reported to SAO.

Many of the laws covered in the previous slides are covered in university policies….

University Policies

• The university has many policies which define employee responsibilities as well as educate and guide employees in understanding rules and expectations of state employment.

• New employees are encouraged to review the web site to become familiar with the university’s policies. The university’s policies are located at http://www.wwu.edu/depts/policies/

Finally, a few slides to provide you with a

basic understanding of a few financial

and accounting terms used at Western…

Financial Responsibilities At Western

“Financial Managers” are those employees at Western that are responsible for financial transactions and fund balances. They are responsible for projecting revenues and expenditures, ensuring that all transactions are appropriate for the fund, the ending year fund

balance is positive, and that there are

sufficient internal controls. Financial Managers

may delegate some responsibilities to another

employee that is referred to as a “Budget Authority.”

Use of State/University Funds

• The university’s monies may only be used for university business purposes.

• These monies are accounted for in the university’s financial system in “Chart 1” funds.

• We all play a role in being good stewards of the public’s money.

Determining Appropriate Use of University Funds

Here are a few questions to help determine the appropriate way to spend university monies:

• Does expenditure serve a public purpose?• Is there a fair exchange of goods

or services?• Does the expenditure appear to

provide a personal benefit?• Does expenditure comply with laws and

university policies?

WWU Foundation Funds

• WWU Foundation is a separate legal entity that solicits donations for the university’s benefit. These monies are recorded into “Chart 2” funds in the financial system.

• Monies are donated for “restricted”

or “unrestricted” purposes and can only be spent in accordance with the donor’s intentions.

Use of “Unrestricted” Foundation Funds

Foundation funds that are not restricted for a specific purpose by the donor must be spent, in general, to support an administrative or academic purpose…not to provide a personal benefit. For example,– Allowable Uses: Scholarships, Fellowships, Academic

Program Support, specific departmental events (search committees) and misc. expenses (hiring and moving new hires)

– Disallowed Uses: Parking permits or tickets, travel to non-work events, and personal gifts.

Welcome to Western !!

If you have any questions or comments, don’t hesitate to call the Internal Audit Office or drop by to see us.

• Director, Matt Babick 650-3435, Old Main 330J• Senior Internal Auditor, Paul Schronen 650-4033, Old Main 330K• Assistant to Internal Audit and Assistant Attorney General, Suzanne

Baker 650-3117, Old Main 331