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Name: Code of Ethical Conduct
Responsible Office: Human Resources

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff , Students

Policy Overview:

Issued: 12-01-2004
Next Review Date: 11-14-2024
Frequency of Reviews: Annually

University of Health Sciences & Pharmacy in St. Louis is committed to maintaining a campus environment that offers a wide range of professional, social and cultural opportunities and where the well-being of students is the primary focus of all decision-making and actions. A Code of Ethical Conduct (the “code”) is in place to avoid conflicts of interest, legal and/or ethics violations and ensure mechanisms are in place to allow for protected reporting of violations.

Applies to faculty, staff, and student workers (including all regular and temporary employees)



In order to promote and sustain a culture consistent with our core institutional value of integrity, University of Health Sciences & Pharmacy in St. Louis (UHSP) expects all employees to conduct themselves in an ethical manner at all times. 

Ethical behavior involves more than character. It is a matter of discerning the difference between right and wrong and choosing to act in the best interests of the University when making decisions, interacting with others, and/or handling University funds, assets and records. In order to ensure the highest ethical standards are maintained, the University adopts the following statements of ethics and professional conduct for its faculty, staff and student workers:

  • Employees will not gain unauthorized access to private or confidential information.
  • Employees will not improperly alter or destroy University records and supporting documentation in violation of the University's recordkeeping policy.
  • Employees will not give anything of value to any person, including public officials and vendors, with the intent to improperly influence any decision or action for the benefit of the employee or the University.
  • Employees will not accept anything of value from a third party except as otherwise permitted under University Policy.
  • Employees will not falsify business expense reimbursement reports or other University records.
  • Employees will not engage in unauthorized or improper political campaign or lobbying activities or use federal funds awarded to the University for such purposes.
  • Employees will not use their positions for personal gain or in a manner which would result in a conflict of interest or undue influence over a decision. Personal gain includes a potential financial benefit or other advantage to the employee or immediate family member. Conflicts of interest may be appropriately managed through disclosure and independent review or decision making to protect the University's interest and/or establish an appropriate management plan. Oversight for this responsibility shall lie with the Faculty Governance Committee (for faculty), Office of Human Resources (for staff) and Board of Trustees (for administration). All research related conflicts of interest will be handled in accordance with the Financial Conflicts of Interest Policy and Guidelines.
  • Employees will only use University funds and assets for appropriate University business in accordance with University policies and applicable laws even if directed otherwise by an individual of higher rank or position.
  • Employees will carry out their duties with honesty, integrity and respect, and all employees will expect honesty, integrity and dignity from others. Specifically, using one’s position to harass or intimidate another member of the administration, faculty, staff or students is a serious violation of this Code.
  • Employees will support the principle of fairness, protect the civil and human rights of others, and obey local, state and national laws. Except in unusual circumstances, employees will normally be given advance notice and an opportunity to respond to complaints of misconduct or performance issues.
  • Employees will maintain the confidentiality of private or confidential information.
  • Employees will understand and have the opportunity to contribute to the formulation and evaluation of the University's mission and policies. Employees will be willing to work with others to support the University in its endeavors to implement its mission.
  • Employees will recognize the potential for conflict of interest and will refrain from engaging in activities that may interfere with the University's mission.
  • Employees have the right to expect to work in a professional and supportive environment and, within the scope of their authority, perform their duties without disruption or harassment. Employees also have the right to refuse to work in unsafe conditions or engage in actions in violation of this Code or any laws.

Employees will communicate potential ethical or law violations to their supervisor, department or division  manager, dean or President's Staff representative, or persons identified in the applicable policies and procedures.   

Additional reporting contacts include the president, director of human resources and/or general counsel. Any concern(s) relating to the president or a trustee may be reported to the chair of the Board of Trustees or the chair of the BOT Audit Committee.

The University has established a hotline administered by an outside vendor to allow members of the University community to file confidential reports of allegations of improper conduct anonymously or by name. The hotline provides an additional method for reporting improper conduct to give individuals another option to supplement reporting procedures under existing policies.

Reports will be promptly reviewed and investigated. In any case where a violation is substantiated, the University may initiate appropriate corrective action.

Employees will not be threatened, retaliated against or punished for making a good faith report alleging unethical or illegal behavior in others.

The administration will ensure these standards of conduct are communicated throughout the University to administration, faculty, staff, and student workers. Managers and supervisors will monitor compliance in their areas.

Failure to adhere to this code of will result in disciplinary action as outlined in the Faculty Handbook and Staff Handbook.

This code will be reviewed periodically by a committee composed of the general counsel, director of human resources, the chair of the Faculty Governance Committee and Staff Council to ensure its effectiveness in furthering the mission of the University.



Employees will communicate potential ethical or law violations to:

  • Your supervisor, department or division manager, dean or President’s Staff representative
  • Responsible office identified in applicable policy or procedure violated. A list of representative offices is a resource to this policy. 
  • Anonymous Reporting
    • Go to for more information
    • File directly online go to
    • Submit a Report by Phone
      • 866.770.0009 for English speaking callers in the USA and Canada (not available from Mexico)
      • 800.216.1288 for Spanish speaking callers North America
      • 800.681.5340 for Spanish speaking callers from Mexico
    • Submit a Report by Email
      • Email reports should be submitted to You must include the company name “UHSP” with report.
    • Submit a Report by Fax
      • Fax reports should be submitted to 215.689.3885. You must include the company name “UHSP” with report.

If the person identified in a complaint is party to the potential problem or ethical violation, an employee may report the matter directly to one of the other options above or directly to the general counsel, president or Board of Trustees (in incidents where the president or a trustee is a party to the problem or violation). The University will comply with all applicable laws and regulations requiring disclosure of fraud, bribery or gratuity violations to government agencies or officials including violations affecting a federal grant award.




Supervisor, department or division manager, dean or President’s Staff Representative

Receiving reports and coordinating with the appropriate office responsible under the identified policy

Responsible office administrator

Responsible for receiving reports and investigating/following up, and reporting


Ensuring Code of Ethical Conduct is communicated to applicable parties


University of Health Sciences & Pharmacy in St. Louis Ethics and Compliance Hotline

Policy Contacts:


Contact Information

Dan Bauer, Director of Human Resources


Ken Fleischmann, General Counsel


Giovanni Pauletti, Interim Dean of Pharmacy


Ehren Bucholtz, Interim Dean of Arts & Sciences


David Allen, President