Introduction
The purpose of this document is to promote honest and ethical conduct of employees having responsibility over and/or access to the financial assets of Syracuse University, and to foster a culture of honesty and financial accountability across the entire University community. Accurate and reliable preparation of financial records is of critical importance in effective management decision-making and in the fulfillment of the University’s financial, legal and reporting obligations. Diligence in accurately preparing and maintaining financial records allows the University to provide full, fair, accurate, timely and understandable disclosure.

While honest and ethical conduct is expected in all aspects of University work from every employee, it is especially true of those employees who have been entrusted with handling the University’s financial affairs. In addition to the University’s Executive Vice President and Chief Financial Officer, the Treasurer, and the Comptroller (together, the “Senior Financial Officers”), these Guidelines are applicable to all University employees whose position or job responsibilities include one or more of the following attributes:

• Head of a division, school, college, or operating department having signatory authority over budgets and/or expenditures.

• Any employee having been granted signatory authority over expenditures on at least one General Ledger account.

• Any employee who has access to confidential financial information (either paper or electronic) pertaining to the University’s business activities, the payroll records of its employees, or the financial records of its students or donors.

• Any employee who has responsibility for handling/processing financial transactions including cash, checks, credit cards, or wire transfers.

Ethical Principles
All employees in management capacities are expected to exhibit and promote the highest standards of honest and ethical conduct through the establishment of, and compliance with, policies and procedures that:

• Promote effective accountability and oversight of financial activities.

• Encourage and reward professional integrity in all aspects of financial activity by eliminating inhibitions and barriers to responsible behavior.

• Proactively promote ethical behavior among subordinates and peers.

• Prohibit and eliminate the appearance or occurrence of conflicts between what is in the best interest of the University and what could result in material personal gain.

• Provide a mechanism for University employees to inform Senior Financial Officers of deviations in practice from policies and procedures governing honest and ethical behavior.

• Demonstrate their personal support for such policies and procedures through periodic communication reinforcing these ethical standards.

• Encourage employees to act in good faith, responsibly, with due care, and diligence, without misrepresenting or omitting material facts or allowing independent judgment to be compromised.

• Educate University employees about federal, state or local laws, rules and regulations that affect their operation.

Operational Guidelines
All employees are expected to adhere to the following guidelines to ensure a) the quality of University financial records and periodic reports, and b) the accountability of the University’s financial assets:

• The physical handling of financial instruments such as cash, checks, credit cards, and related receipts must be done in a sufficiently secure manner as to prevent loss or misappropriation.

• Only those financial transactions representing legitimate University business activities are to be processed through the University accounts.

• Accounting records, as well as reports produced from those records, must be kept and presented in accordance with applicable laws.

• Business transactions must be properly authorized and completely and accurately recorded on the University’s books and records in accordance with Generally Accepted Accounting Principles (GAAP) and established University financial policies.

• Records must fairly and accurately reflect the transactions or occurrences to which they relate.

• Records must fairly and accurately reflect in reasonable detail the University’s assets, liabilities, revenues and expenses.

• Accounting records must not contain any intentionally false or misleading entries.

• Transactions must not be intentionally misclassified as to accounts, departments or accounting periods or in any other manner.

• Transactions must be supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period.

• Periodic financial communications and reports will be delivered in a manner that facilitates the highest degree of clarity of content and meaning so that readers and users will quickly and accurately determine their significance and consequence.

• The retention or proper disposal of University records shall be in accordance with established University financial policies and applicable legal and regulatory requirements.

• Sensitive or confidential Information acquired during the performance of job responsibilities must be respected and kept confidential, except when disclosure is authorized by an appropriate University official or legally compelled. Confidential information acquired during the performance of job responsibilities must not be used for personal advantage.

• Information must not be concealed from the internal auditors or the independent external auditors.