December 15, 2007 Page 1 of 4 Administrative Guide Memo 1

University Code of Conduct

Authority This Guide Memo was approved by the President.

Applicability This Code applies to the following members of the Stanford University Community: a) Individuals
who are paid by Stanford University when they are working for the University — this category
includes faculty, staff and students; b) when required by contract, consultants, vendors, and
contractors when they are doing business with the University; c) individuals who perform services
for the University as volunteers and who assert an association with the University; and d) students.
The Code refers to all these persons as “members of the University community” or “community
members.”
Summary This Guide Memo defines the University’s Code of Conduct. Section headings are:
1. INTRODUCTION AND PURPOSE
2. STANDARDS OF INTEGRITY AND QUALITY
3. CONFIDENTIALITY AND PRIVACY
4. CONFLICT OF INTEREST/CONFLICT OF COMMITMENT
5. HUMAN RESOURCES
6. FINANCIAL REPORTING
7. COMPLIANCE WITH LAWS
8. USE OF UNIVERSITY RESOURCES
9. REPORTING SUSPECTED VIOLATIONS

1. INTRODUCTION AND PURPOSE

a. Introduction — As members of the Stanford University community, all faculty, staff, students,
members of the Board of Trustees, University Officers and affiliates are responsible for sustaining the
highest ethical standards of this institution, and of the broader community in which we function. The
University values integrity, honesty and fairness and strives to integrate these values into its teaching,
research and business practices.
b. Purpose — In that spirit, this Code (the “Code”) is a shared statement of our commitment to upholding
the ethical, professional and legal standards we use as the basis for our daily and long-term decisions
and actions. We all must be cognizant of and comply with the relevant policies, standards, laws and
regulations that guide our work. We are each individually accountable for our own actions and, as
members of the University community, are collectively accountable for upholding these standards of
behavior and for compliance with all applicable laws and policies.
c. Violations — Adherence to this Code also makes us responsible for bringing suspected violations of
applicable standards, policies, laws or regulations to the attention of the appropriate cognizant office.
Raising such concerns is a service to the University and will not jeopardize one’s position or
employment. Confirmed violations will result in appropriate disciplinary action up to and including
termination from employment or other relationships with the University. In some circumstances, civil
and criminal charges and penalties may apply.
d. Questions — Any questions regarding the intent or applicability of this Code should be directed to the
Director of Institutional Compliance, http://institutionalcompliance.stanford.edu/, or Office of the
General Counsel, http://www.stanford.edu/dept/legal/index.html.

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2. STANDARDS OF INTEGRITY AND QUALITY

Stanford recognizes that it must earn and maintain a reputation for integrity that includes, but is not limited
to, compliance with laws and regulations and its contractual obligations. Even the appearance of
misconduct or impropriety can be very damaging to the University. Stanford must strive at all times to
maintain the highest standards of quality and integrity.
Frequently, Stanford’s business activities and the other conduct of its community members are not
governed by specific laws or regulations. In these instances, rules of fairness, honesty, and respect for the
rights of others will govern our conduct at all times.
In addition, each individual is required to conduct University business transactions with the utmost
honesty, accuracy and fairness. Each situation needs to be examined in accordance with this standard. No
unethical practice can be tolerated on the grounds that it is “customary” outside of Stanford or that it serves
other worthy goals. Expediency should never compromise integrity.

3. CONFIDENTIALITY AND PRIVACY

Community members receive and generate on behalf of the University various types of confidential,
proprietary and private information. It is imperative that each community member complies with all
federal laws, state laws, agreements with third parties, and University policies and principles pertaining to
the use, protection and disclosure of such information, and such policies apply even after the community
member’s relationship with Stanford ends.
Information on the University’s “Principles of Privacy” or on specific privacy laws, such as the Family
Educational Rights and Privacy Act (FERPA – student records); Health Insurance Portability and
Accountability Act (HIPAA – personal health information); California Civil Code section 1798.85 (social
security numbers); and Civil Code section 3426 (trade secrets) may be obtained from the Office of the
General Counsel, http://www.stanford.edu/dept/legal/.
Additionally, any privacy rights in information stored on University computer systems are governed by
Administrative Guide Memo 62, Computer and Network Usage Policy,
http://adminguide.stanford.edu/62.pdf, and the Academic Policies and Statements for students,
http://www.stanford.edu/dept/registrar/bulletin.

4. CONFLICT OF INTEREST/CONFLICT OF COMMITMENT

Community members who are Stanford faculty and staff owe their primary professional allegiance to the
University and its mission to engage in the highest level of education, patient care, research and
scholarship. Outside professional activities, private financial interests or the receipt of benefits from third
parties can cause an actual or perceived divergence between the University mission and an individual’s
private interests. In order to protect our primary mission, community members with other professional or
financial interests shall disclose them in compliance with applicable conflict of interest/conflict of
commitment policies, which are available on the following websites:
• Faculty Policy on Conflict of Commitment and Interest:
http://www.stanford.edu/dept/DoR/rph/4-1.html
• Staff Policy on Conflict of Commitment and Interest: http://adminguide.stanford.edu/15_2.pdf
• Academic Staff Policy on Conflict of Commitment and Interest:
http://www.stanford.edu/dept/DoR/rph/4-4.html

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5. HUMAN RESOURCES
Stanford University is an institution dedicated to the pursuit of excellence and facilitation of an
environment that fosters this goal. Central to that institutional commitment is the principle of treating each
community member fairly and with respect. To encourage such behavior, the University prohibits
discrimination and harassment and provides equal opportunities for all community members and
applicants regardless of their race, color, religious creed, national origin, ancestry, physical or mental
disability, medical condition, marital status, sex, age, sexual orientation, gender identity, veteran status or
any other characteristic protected by law. Where actions are found to have occurred that violate this
standard the University will take prompt action to cease the offending conduct, prevent its recurrence and
discipline those responsible. Specific policies in support of this standard are found at these locations:
• General Personnel Policies: http://adminguide.stanford.edu/23.pdf
• Diversity & Access Office: http://www.stanford.edu/dept/diversityaccess/
• Sexual Harassment Policy Office: http://www.stanford.edu/dept/shpo/
• Policy on Sexual Harassment and Consensual or Romantic Relationships:
http://adminguide.stanford.edu/23_2.pdf
• Policy on Sexual Assault: http://adminguide.stanford.edu/23_3.pdf
The University shall also comply with all laws and regulations governing the circumstances under which
former United States military personnel may be employed or retained as consultants.

6. FINANCIAL REPORTING
All University accounts, financial reports, tax returns, expense reimbursements, time sheets and other
documents, including those submitted to government agencies, must be accurate, clear and complete. All
entries in University books and records, including departmental accounts and individual expense reports,
must accurately reflect each transaction. See Administrative Guide Memos 34, Responsibility for University
Financial Assets, http://adminguide.stanford.edu/34.pdf, and 34.5, Cost Policy,
http://adminguide.stanford.edu/34_5.pdf.

7. COMPLIANCE WITH LAWS

Members of the University community must transact University business in compliance with applicable
laws, regulations, and University policy and procedure. Managers and supervisors are responsible for
teaching and monitoring compliance. When questions arise pertaining to interpretation or applicability of
policy, contact the individual who has oversight of the policy. Unresolved questions and/or interpretation
of laws and regulations should be referred to the Office of General Counsel. University-wide policy
documents can be found at http://www.stanford.edu/home/administration/policy.html.
a. Contractual Obligations — The acceptance of an agreement, including sponsored project funding, may
create a legal obligation on the part of Stanford University to comply with the terms and conditions of
the agreement and applicable laws and regulations. Therefore, only individuals who have authority
delegated by an appropriate University official are authorized to enter into agreements on behalf of the
University. See Administrative Guide Memo 52, Procurement Relationships,
http://adminguide.stanford.edu/52.pdf.
b. Environmental Health & Safety, including Workplace Health and Safety — Members of the
University community must be committed to protecting the health and safety of its members by
providing safe workplaces. The University will provide information and training about health and
safety hazards, and safeguards. Community members must adhere to good health and safety practices
and comply with all environmental health and safety laws and regulations. See
http://www.stanford.edu/dept/EHS/prod/training/intro/ppribm.pdf.

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c. Non-University Professional Standards — Some professions and disciplines represented at the

University are governed by standards and codes specific to their profession (such as attorneys, certified
public accountants, and medical doctors). Those professional standards generally advance the quality
of the profession and/or discipline by developing codes of ethics, conduct, and professional
responsibility and standards by which their members are guided. Those belonging to such
organizations are expected to adhere to University policies and codes of conduct in addition to any
professional standards. If a community member believes there is a conflict between a professional
standard and University policy, he/she should contact the Office of the General Counsel.
d. Academic Policies — See http://www.stanford.edu/dept/registrar/bulletin for academic policies.

8. USE OF UNIVERSITY RESOURCES

University resources must be reserved for business purposes on behalf of the University. They may not be
used for personal gain, and may not be used for personal use except in a manner that is incidental, and
reasonable in light of the employee’s duties. University resources include, but are not limited to, the use of
University systems, such as telephone systems, data communication and networking services, and the
Stanford domain for electronic communication forums; and the use of University equipment, such as
computers and peripherals, University vehicles and other equipment; and the use of procurement tools
such as purchasing cards and petty cash; and the time and effort of other staff, students and others at
Stanford.

9. REPORTING SUSPECTED VIOLATIONS

a. Reporting to Management — Members of the Stanford community should report suspected violations
of applicable laws, regulations, government contract and grant requirements or this Code. This
reporting should normally be made initially through standard management channels, beginning with
the immediate supervisor, instructor or advisor. If for any reason it is not appropriate to report
suspected violations to the immediate supervisor (e.g., the suspected violation is by the supervisor)
individuals may go to a higher level of management within their school or department.
b. Other Reporting — All violations of laws or regulations should be reported internally to the
Institutional Compliance Helpline (compliance@stanford.edu or 650/725-0076) or to the Office of the
General Counsel (650/723-9611). Any suspected violations of rules regarding federal funds may also
be reported to the Department of Defense Fraud, Waste, and Abuse Hotline at 800/424-9098. In
addition, any suspected violations of state or federal statutes, rules or regulations may also be reported
to the California Attorney General's Whistleblower Hotline at 800/952-5225.
c. Confidentiality — Such reports may be made confidentially, and even anonymously, although the
more information given, the easier it is to investigate the reports. Raising such concerns is a service to
the University and will not in itself jeopardize employment.
d. Cooperation — All employees are expected to cooperate fully in the investigation of any misconduct.

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