Approved by:	The President (Originally Approved by Board of Trustees)
History:	Issued - December 16, 2014
	Revised - September 8, 2023
	Last Reviewed - September 8, 2023
Related Policies:
Additional References:
Policy Owner:	Office of the President, tel. (202) 319-5100
Contact Person:	Office of the Provost, tel. (202) 319-5244 Associate Vice President and Chief HR Officer, tel. (202) 319-5050

As the national university of the Catholic Church in the United States, The Catholic University of America is committed to being a comprehensive Catholic institution faithful to the teachings of Jesus Christ as handed on by the Church. Faithful to the University's Catholic Intellectual Tradition and Mission  the University has unique responsibilities to be of service to Christian thought and education in the Catholic community, to promote Catholic social teaching, and to serve the nation and the world.

Regardless of our religious affiliation, each of us must honor the University's mission and adhere to the commitments set forth in this Code of Conduct, which forms the foundation for the University's Compliance and Ethics Program (http://compliance.cua.edu/). This Code of Conduct applies to all staff and faculty, student employees, and vendors and contractors acting on behalf of the University.

Our Commitment to the University and the Community

The University's distinctive character and its ability to meet its responsibilities to Church and nation depend upon the decisions we make as members of the University community. Accordingly we must:

• Discharge our duties in good faith and in a manner that will advance the University's values and mission, safeguard its human, financial and physical resources, and protect its academic and research reputations;
• Take individual responsibility and be accountable for our own actions;
• Be stewards for the property and resources entrusted to us and protect them against theft or misuse;
• Protect the privacy of students, employees, donors and others who entrust confidential, privileged, or proprietary information to us, and use such information only for the purposes for which access was provided;
• Ensure all documents prepared or used in furtherance of University operations are accurate and complete;
• Avoid even the appearance of impropriety and exercise care so that our personal relationships and interests do not result in situations that conflict with the University's interest or interfere with our objective judgment;
• Act honestly, fairly, and courteously at all times towards students, parents, advisees, colleagues and members of the greater community;
• Promote a culture of equality, inclusiveness and diversity free from unlawful discrimination; and
• Refrain from abusing the authority entrusted to us or harassing others.

Our Commitment to Following Applicable Laws and Standards

We each must comply with all laws and policies pertaining to our positions and activities. All University-wide policies are published on the University Policy website (http://policies.cua.edu). Questions about the application of policies can be directed to the Responsible Official listed in the policy or to the Chief Ethics and Compliance Officer and Chief Privacy Officer (tel. 202-319-6170, CUA-COMPLIANCE@CUA.EDU).

If situations arise where a specific law or University policy does not govern, we should seek guidance from our supervisor, from a University Official who has responsibility for the area in question, or from the Chief Ethics and Compliance Officer and Chief Privacy Officer (tel. 202-319-6170, CUA-COMPLIANCE@CUA.EDU) or the Office of General Counsel (tel. 202-319-5142, CUA-OGC@CUA.EDU).

Our Commitment to Report Unethical Conduct

We are all responsible for bringing suspected unethical conduct to the attention of University officials when we have a good faith belief that the conduct has occurred. Unethical conduct means non-compliance with a law, University policy, the Code of Conduct, or other standard or requirement applicable to the University.

Good faith means a report based on an incident of possible wrongdoing or abuse made without malice, for which the person reporting has reasonable cause to believe wrongdoing or abuse occurred.

Knowingly initiating or causing to be initiated any false or bad faith report, warning or threat, including but not limited to, a false or bad faith report for the purpose of retaliation or based solely on any protected traits, is strictly prohibited.

All inquiries, and all good faith reports of suspected non-compliance regardless of whether they are substantiated and regardless of the method of reporting, can be made free from fear of retaliation per the University's Non-Retaliation Policy (http://policies.cua.edu/governance/nonretaliation.cfm).

Matters that must be reported include, but are not limited to:

• Theft, fraud, or other financial irregularity;
• Misuse of University resources;
• Misuse of grant funds;
• Activities undertaken for personal benefit or the benefit of family or friends at the expense of the University (conflicts of interest);
• Unlawful discrimination; or
• Crimes of violence.

Wherever possible, we should report our concerns by talking with our supervisor or a University official who has responsibility for the area of concern, or by contacting the Chief Ethics and Compliance Officer and Chief Privacy Officer (tel. 202-319-6170, CUA-COMPLIANCE@CUA.EDU) who will respond promptly and confidentially to the extent possible by law. Concerns also may be raised anonymously using the University's Compliance and Ethics Helpline (toll free at tel. 855-350-9396 or online at https://secure.ethicspoint.com/domain/media/en/gui/31756/index.html).

The University will investigate all reports of suspected non-compliance, regardless of source, and implement corrective action or disciplinary action when necessary. We are all responsible for cooperating with investigations.

Approved by the Board of Trustees December 16, 2014

Last substantive review December 17, 2019 (typo corrected March 28, 2022)