Ethics and Compliance Framework

When members of the university community operate ethically and with integrity, it generates trust, enhances communication, improves the university’s culture, and supports the university’s mission. An ethical environment encourages:

• Honesty, integrity, and responsible decision-making and actions
• Fairness and respect for others
• Innovation
• Sustainability
• Stewardship of the resources entrusted to fulfill UB’s mission of teaching, research, and public service
• Safe and healthy workplaces

The foundation of UBs ethical culture is rooted in our Principles of Ethical Conduct guiding us in ethical decision-making, supporting key university policies, and emphasizing our obligation to avoid conflicts of interest and report misconduct or non-compliant behavior.

The Principles of Ethical Conduct promotes these ethical decision-making values:

• Honesty and Integrity: act in good faith and with the highest standards of ethical conduct
• Respect: our commitment to inclusiveness, diversity, and mutual respect for differences
• Stewardship and Compliance: careful and responsible management of university resources
• Accountability and Responsibility: willingness to take responsibility for our choices and actions

All members of the university community are responsible for maintaining the highest ethical standards of excellence, integrity, honesty, and fairness and for integrating these values into teaching, research, business practices, and other services. Ethical conduct is a fundamental expectation for every university community member.

Compliance and ethics are essential aspects of the university’s operations. Compliance means adhering to laws, regulations, and internal policies, while ethics involves conducting business in a morally responsible manner. Together, compliance and ethics create a framework that guides behavior towards responsible and lawful actions.

Compliance ensures that the university operates within the boundaries set by external regulators and internal policies. Failure to comply with these regulations can result in legal consequences, reputational damage, and financial loss.

Ethics, on the other hand, goes beyond compliance and focuses on doing what is right. UB’s strong ethical culture prioritizes honesty, integrity, fairness, and respect in all dealings. Ethical behavior not only contributes to a positive work environment but also builds trust and credibility with stakeholders. Compliance and ethics are interrelated, as ethics forms the foundation for compliance.

Employees who understand and embrace ethical principles are more likely to comply with regulations and internal policies. Honest, informed, and responsible conduct by faculty, staff, and students can help the university meet compliance requirements. 

But internal controls have value beyond compliance and reporting. Good internal control practices allow the university to achieve its objectives while maintaining an environment that focuses on ethics and accountability.

Key components of internal controls include:

• Control Environment - the foundation of internal control, reflecting the organization's overall attitude towards ethics, integrity, and control consciousness
• Risk Assessment – process to identify and analyze potential risks that could impact the university's objectives
• Control Activities – specific actions to mitigate identified risks including:
  • Segregation of duties
  • Access controls
  • Reconciliations
  • Approvals and authorizations
• Information and Communications - systems for capturing, processing, and communicating relevant information throughout the organization
• Monitoring Activities – ongoing evaluations to assess the effectiveness of internal controls and identify deficiencies

Everyone at the university is responsible for internal controls and plays a critical role in fostering a strong internal control environment. In an effective control environment, competent people understand their responsibilities and the limits of their authority, and are knowledgeable, mindful, and committed to doing what is right.

The university’s Internal Controls Policy reinforces our commitment to a strong system of internal controls focused on accountability and oversight of operations to reasonably assure that the university:

• Meets its mission
• Promotes performance leading to effective accomplishment of objectives and goals
• Safeguards assets
• Provides accurate and reliable financial and other key data
• Promotes operational efficiency and economy
• Encourages adherence to applicable laws, regulations, policies, and practices

UB’s policy process is guided by the following principles:

• The policy process is well-defined, understandable, and transparent
• University community input and feedback are broadly sought, valued, and appropriately used
• Policy ownership lies with the responsible office and executive
• Policy owners are responsible for reviewing, updating, and retiring policies as needed
• Supervisors, managers, and individuals are responsible for understanding, implementing, and enforcing university policies, rules, and unit governing documents

The Policy Office:

• Maintains the University Policy Library, the official repository of active university policies
• Maintains the official university policy template Download pdf
• Provides guidance for policy planning, development, writing, and promulgation
• Administers the Policy Review Group
• Is the responsible office and policy owner for the Developing University Policies Policy

The  Policy Review Group (PRG) supports the policy process by reviewing new policies and revisions to existing policies. The PRG provides a university-wide perspective as well as advice and recommendations so that policies best reflect the needs of the institution and support the university’s mission. The review process ensures that policies are understandable, implementable, and cost-effective.

Members of the university community may report concerns or seek guidance regarding potential or actual misconduct or noncompliance with laws, regulations, and university policies without fear of retaliation. This includes the ability to report anonymously via EthicsPoint, a confidential reporting channel.

Reporting via EthicsPoint is safe and confidential — no retaliatory action will be taken against anyone for reporting or inquiring, in good faith, about potential breaches of university policies or procedures or for seeking guidance on how to manage suspected misconduct.

EthicsPoint offers both telephone and web-based reporting options:

• EthicsPoint secure website:  www.buffalo.ethicspoint.com
• EthicsPoint confidential hotline:  844-678-0455 toll-free within the U.S., Canada, Puerto Rico and Guam; available 24 hours a day, 7 days a week

The university encourages employees to attempt to resolve concerns or work-related issues with supervisors through established channels whenever possible. However, if making a report to a supervisor is uncomfortable or inappropriate, other reporting options are available.