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Responsible Official: Vice President for Policy and General Counsel
Specific
Authority: 1001.61 - 65, 1004.70 FS.
Law
Implemented: 1001.61 - 65, 1004.70 FS.
Effective Date: 11-20-01
Policy Statement:
Members of the District Board of Trustees and College employees shall be governed at all times by the applicable provisions of the Code Of Ethics For Public Officers And Employees (ss. 112.311-112.326, F.S.), as may be amended from time to time, with regard to matters including:
Solicitation or acceptance of gifts
Doing business with one's agency
Unauthorized compensation
Misuse of public position
Conflicting employment or contractual relationship
Disclosure or use of certain information
Voting conflicts.
Filing statements of financial interests
Members of the District Board of Trustees and College employees shall be governed at all times by the applicable provisions of the Florida Government in the Sunshine Law, Section 286.011, Florida Statutes, and the Public Records Act, Chapter 119, Florida Statutes, and related statutes and rules, all as may be amended from time to time.
Valencia Community College, under the governance of its Board of Trustees, is committed to the highest standards of moral and ethical behavior. Breaches of these standards, through acts of gross mismanagement, malfeasance, misfeasance, gross waste of public funds or gross neglect of duty by the College, its employees or independent contractors, or through any violation or suspected violation of any federal, state, or local law, rule, or regulation committed by the College, its employees or independent contractors which creates and presents a substantial and specific danger to the public's health, safety, or welfare (Improper Activities), are not only costly, but tend to erode the public's trust and confidence in the integrity of the College. By issuing this formal policy statement, the College hereby reaffirms its duty and responsibility to aggressively combat such conduct and performance.
This policy is intended to (1) communicate clearly that Improper Activities are strictly prohibited, unacceptable, and will not be tolerated (2) institute preventive measures designed to deter these activities or make them easier to detect and stop, and (3) provide for the reporting and investigation of such activities, including providing protection to persons who report violations.
It is the policy of Valencia Community College to ensure that employees who have knowledge of Improper Activities or suspected Improper Activities shall report such knowledge to the appropriate authority for investigation and corrective action. In order to encourage reporting of such information without fear of reprisal, it shall be the policy of the College to prohibit and redress adverse personnel action taken against employees for making such a protected disclosure. An employee who, in good faith, reports wrongful activity meeting the provisions of Section 112.3187, Florida Statutes (Whistleblower's Act), is protected against adverse personnel actions (Retaliation) for making such a report. The law also provides for the reporting individual's identity to remain confidential, unless the disclosure of the individual's identity is necessary to prevent a substantial and specific danger to the public's health, safety, or welfare or to prevent the imminent commission of a crime; or the disclosure is unavoidable and absolutely necessary during the course of the audit, evaluation, or investigation.
Internal Controls: Responsibility for Detection, Reporting and Prevention
College employees at all levels of management shall set the appropriate tone by displaying the proper attitude toward complying with laws, rules and regulations. Supervisors are also responsible for establishing and maintaining proper internal controls that will provide for the security and accountability of the resources entrusted to them. Such controls include, but are not limited to, ensuring that (1) incompatible duties are properly separated, (2) financial transactions are properly authorized and approved, (3) reports of financial activity are periodically reviewed for completeness and accuracy, (4) official personnel actions (ex: appointments, terminations, promotions) and employee time and leave is properly authorized and approved, (5) assets are physically secured, (6) computer passwords are protected and not shared, (7) confidential and sensitive information is protected from unauthorized access, and (8) employees are effectively supervised. In addition, employees shall be cognizant of the risks and exposures inherent in their area of responsibility, take appropriate steps to help mitigate those risks and be aware of the related symptoms of Improper Activities. Employees shall be alert to the possibilities of Improper Activities and for any indication that Improper Activities are taking place.
Related Documents and Policies:
History:
Replaced former Policies 6Hx28:01-00, 6Hx28:02-00, 6Hx28:02-01, 6Hx28:02-02, 6Hx28:02-03, 6Hx28:02-05, 6Hx28:04-01 and 6H28:04-02: 11-20-01; Formerly 6Hx28:01-09; Amended 7-1-09. Revised, updated and approved on 6-16-09.