October University Policy Distribution
The October university policy distribution contains one (1) revised policy, one (1) revised guidance document, and two (2) new guidance documents.
Revised Policies
Revised Guidance
New Guidance
- SYS 1290 Guidance: Guidance for Reporting and Mitigating Nepotism and Consensual Relationships
- SYS 1290 Guidance, Guidance for Filing Statements of Economic Interest Under UWS 8.06
Click on the links above to view the drafts and ensure that your feedback is captured for review during the post-comment period. Comments can include attachments, including word documents and PDFs. Feedback on the items above is due at 5:00 pm on Friday, November 13.
DRAFT POLICY REVISIONS
SYS 1290, Code of Ethics
These policy revisions will be effective upon the signature of President.
Summary of Policy and Policy Revisions
- In 2023, the University of Wisconsin System Office of Internal Audit performed an audit on institutional compliance with Nepotism and Conflict of interest statutes and university polices. The recommended revisions to SYS 1290, Code of Ethics and new guidance documents are in response to audit findings and recommendations.
- All UW System employees must act according to the highest ethical and professional standards of conduct. The purpose of this policy and accompanying guidance documents is to provide comprehensive operational direction on how to educate employees and fulfil mandatory reporting requirements on their applicable Code of Ethics.
- Key revisions to the policy include:
- In Section 2, changing the responsible officer from the UW System Director of Compliance to the Associate Vice President and Chief Human Resources Officer.
- In Section 4, specifying that associate and assistant vice presidents and Rural Health Development Council members are also subject to subchapter III of Wis. Stats. Chapter 19.
- In Section 6.B, adding language to specify who employees should contact when they have questions on ethics requirements in the state code, statute, or regent policy document.
- In Section 6.C, adding language to specify which employees must file a statement of economic interest and adding a reference to the new guidance document SYS 1290 Guidance: Guidance for Filing Statements of Economic Interest Under UWS 8.06
DRAFT REVISED GUIDANCE
SYS 1290 Guidance: Guidance for Reporting Outside Activities Under UWS 8.06
These guidance revisions will be effective upon the signature of the Associate Vice President and Chief Human Resource Officer.
Summary of Guidance and Guidance Revisions
- In 2023, the University of Wisconsin System Office of Internal Audit performed an audit on institutional compliance with Nepotism and Conflict of interest statutes and university polices. The recommended revisions to SYS 1290, Code of Ethics and new guidance documents are in response to audit findings and recommendations.
- This guidance supports UW System Administrative Policy 1290, Code of Ethics and describes specific requirements for reporting outside activities for unclassified staff.
- Key revisions include:
- Adding language in Section 1 to specify the guidance describes reporting requirements for unclassified staff.
- Adding language to Section 3 to align the guidance with SYS 1290, Code of Ethics that the guidance applies to unclassified staff who have half-time or greater appointments.
- Deleting language in Section 4 relating to conflict of commitments.
- Moving Definitions subsection to 5.A (from 5.B) and adding definitions of “immediate family member” and “reportable outside activities.”
- Adding new subsection Section 5.B.III (formerly Section 5.A) relating to the timing of outside activity report submissions and specifying that significant changes to a report that occur throughout the year must be immediately reported.
- Adding language to Section 5.C specify that:
- review of outside activity reports should be done in alignment with an institution’s policies
- reports should be reviewed throughout the year if there is a significant change to a staff member’s reportable outside activities
- report reviewers should consult with appropriate offices (Officer of Human Resources, Office of Compliance, etc) as necessary when meeting with a staff member to create a conflict-of-interest mitigation plan
- Deleting subsection 5.C.I.1 and 5.D.
DRAFT NEW GUIDANCE
SYS 1290 Guidance: Guidance for Reporting and Mitigating Nepotism and Consensual Relationships
This guidance will be effective upon the signature of the Associate Vice President and Chief Human Resource Officer.
Summary of Guidance
- In 2023, the University of Wisconsin System Office of Internal Audit performed an audit on institutional compliance with Nepotism and Conflict of interest statutes and university polices. The recommended revisions to SYS 1290, Code of Ethics and new guidance documents are in response to audit findings and recommendation.
- This guidance describes specific requirements for reporting and mitigating potential nepotism and reporting and mitigating adverse impacts associated with consensual relationships.
- In April 2024, similar draft language was distributed for feedback as a part of SYS 1290 Guidance, Guidance for Reporting Outside Activities Under UWS 8.025. This draft guidance document incorporates revisions made in response to feedback from the prior draft distribution, including making this a standalone guidance document.
SYS 1290 Guidance: Guidance for Filing Statements of Economic Interest Under UWS 8.06
This guidance will be effective upon the signature of the Associate Vice President and Chief Human Resource Officer.
Summary of Guidance
- In 2023, the University of Wisconsin System Office of Internal Audit performed an audit on institutional compliance with Nepotism and Conflict of interest statutes and university polices. The recommended revisions to SYS 1290, Code of Ethics and new guidance documents are in response to audit findings and recommendation.
- This guidance describes specific requirements for filing statements of economic interests under Wisconsin Administrative Code UWS 8.06, Subchapter III of Chapter 19 of Wisconsin Statutes, and Regent Policy Document 21-9, Institutional Relationships with Foundations.
Federal Fridays
The Universities of Wisconsin Federal Update Working group has a Federal Updates web page for the public to learn about the federal issues the UW is monitoring. The site provides a dashboard view of the various issues organized by topic, with a summary and links related to the topic.