CONDUCT ETHICAL EMPLOYEE
PURPOSE
Florida Gulf Coast University (FGCU) is committed to fostering a culture of integrity, accountability and respect in all aspects of university life. The Employee Code of Ethical Conduct (Code) serves as a foundational guide for ethical and professional behavior for all employees of the FGCU community.
The Code is designed to help employees recognize and resolve compliance and ethics issues. It provides general information and practical guidance about behavior expectations and highlights key FGCU regulations and policies that apply to the work we do. It also identifies resources and contacts for seeking advice or reporting concerns. Consider this Code your roadmap for doing the right thing and soaring with integrity.
Our Code governs all University decisions and actions, whether in administrative offices, classrooms, laboratories, athletic facilities, or open campus spaces. It applies to the President and Cabinet, faculty, staff, student employees, volunteers, contractors, contingent workers, vendors and other representatives providing services to or acting on behalf of FGCU.
The Chief Ethics and Compliance Officer is responsible for promoting, monitoring and enforcing the Code, while every member of our community shares responsibility for upholding it and contributing to FGCU’s ethical culture of excellence. A separate Student Code of Conduct governs student behavior when acting in an academic or campus capacity.
As members of the FGCU community, we are expected to be civil, show mutual respect, practice sustainability, prioritize our students, take pride in green and blue and, of course, watch out for alligators.
MISSION
Florida Gulf Coast University (FGCU) is a transformative, learner-centered institution dedicated to student success that strategically serves Southwest Florida and beyond.
VISION
Florida Gulf Coast University aspires for national prominence and global recognition as a community-focused, comprehensive institution driving positive change and shaping the future of higher education.
STATEMENT OF FREE EXPRESSION
Florida Gulf Coast University vigorously protects freedom of inquiry and expression and categorically expects civility and mutual respect to be practiced by faculty, students and staff in all deliberations on its campus. As such, the FGCU community as well as the Florida Gulf Coast University Board of Trustees shares the commitment of the State University System of Florida and the Florida Board of Governors to civil discourse and endorses their commitment with this Statement of Free Expression.
CORE VALUES
At FGCU, our guiding values of curiosity, collaboration and commitment drive innovation, foster community and inspire excellence.
1 2 3
CURIOSITY
We pursue knowledge with openness, creativity and determination.
At FGCU, we:
• Ask and invite challenging questions.
• Explore innovative ideas and perspectives.
• Develop forward-thinking, strategic solutions.
• Drive positive change through critical thinking and decisive action.
COLLABORATION COMMITMENT
We lead with integrity and responsibility for progress and performance.
At FGCU, we:
• Engage in continuous improvement.
• Hold ourselves accountable.
• Achieve high-quality outcomes.
• Persevere through challenges.
We work together to achieve common goals.
At FGCU, we:
• Communicate with respect to strengthen our community.
• Break down barriers that hinder collective success.
• Partner across campus to leverage our talents.
• Empower each other to be our best selves.
WHO MUST FOLLOW THIS CODE
This Code applies to all individuals who represent or act on behalf of Florida Gulf Coast University, including:
• The President and Cabinet.
• Faculty, staff, OPS and student employees.
• Volunteers, contractors, contingent workers, vendors and other representatives providing services to or acting on behalf of FGCU.
The Chief Ethics and Compliance Officer is responsible for promoting, monitoring and enforcing this Code. Each member of the University community is responsible for understanding and upholding the standards outlined in this Code to support FGCU’s ethical culture.
A separate Student Code of Conduct applies to students when acting in their capacity as students in academic, residential, or campus settings.
The following exclusion applies:
The University acknowledges and appreciates the Board of Trustees’ support of the University’s compliance and ethics program. This Code does not apply to members of the Florida Gulf Coast University Board of Trustees. Trustees are subject to separate ethics requirements established under applicable Florida law and the regulations of the Florida Board of Governors, including standards administered by the Florida Commission on Ethics.
GENERAL PRINCIPLES
FGCU relies on you to represent the institution and its mission, vision and core values. You are expected to conduct yourself and the University’s operations with honesty and integrity and in conformance with University policies and regulations, as well as state and federal laws, rules and regulations.
The following ethical principles are intended to guide your interactions with both internal and external constituents.
Integrity and honesty
All members of the FGCU community are expected to act with integrity, honesty and ethical responsibility in every aspect of their work. Fairness and good faith should guide all professional interactions, especially those involving students, research sponsors, alumni, vendors, volunteers and donors. If you are unsure whether a particular action is appropriate, it is important to consult with trusted colleagues, supervisors, or university administrators to ensure your decisions align with the University’s values. FGCU personnel are expected to demonstrate ethical, legal, and professional behavior in teaching, research, public service and business practices.
Respect and civility
Florida Gulf Coast University is committed to treating all members of the University community, including students, faculty, staff, administrators and visitors, with dignity and consideration. Discrimination, harassment, emotional abuse, or any form of assault based on race, color, religion, age, disability, sex, pregnancy status, national origin, marital status, genetic predisposition, sexual orientation, veteran status, or any other legally protected status is prohibited.
Employees contribute to a positive environment by:
• Recognizing and valuing the talents, abilities and experiences of others.
• Respecting the contributions and perspectives of colleagues and students.
• Promoting openness, trust and constructive dialogue in all interactions.
FGCU community members are expected to foster a culture of tolerance, mutual respect and openness, honoring the rights and dignity of others regardless of differences. Professionalism and civility should be maintained in all workplace interactions. Individuals are encouraged to conduct themselves in a positive, collegial and respectful manner, collaborating effectively with fellow community members and external partners.
Positive contributions to a welcoming environment include:
• Using language that is welcoming and considerate.
• Respecting different perspectives and backgrounds.
• Responding to constructive feedback with openness.
• Prioritizing the well-being and success of the community.
• Demonstrating empathy and consideration for others.
Behaviors that are considered inappropriate and unacceptable include:
• Using sexualized language, imagery, or making unwelcome sexual advances.
• Engaging in trolling, making offensive remarks, or launching personal or political attacks.
• Harassing others, whether publicly or privately.
• Sharing someone’s private information (e.g., addresses) without their explicit consent.
• Any other actions that would be deemed unprofessional or nappropriate in a working or learning environment.
Professional Conduct Expectations as a Public Employee
FGCU expects all employees to model professionalism, integrity and respect in their daily interactions, including conduct that occurs beyond the campus setting when it may reflect on the university. To support a positive, ethical, and collaborative work environment, employees are expected to:
• Treat all members of the FGCU community with dignity and mutual respect, including colleagues, students, visitors and external partners.
• Honor commitments and follow through on agreements, demonstrating reliability and earning the trust of others.
• Communicate openly, honestly and constructively, even when addressing difficult issues or differing viewpoints.
• Resolve disagreements in good faith, seeking solutions that promote collaboration, understanding and shared success.
• Avoid behavior that undermines or diminishes others, including actions that erode trust, damage working relationships, harm the University’s reputation, or disrupt the professional environment.
• Engage in positive, respectful and accountable conduct, contributing to a workplace culture where all members feel valued and supported.
• Promote informal conflict resolution whenever appropriate, addressing concerns early and respectfully to maintain a healthy and productive workplace climate.
These expectations reflect FGCU’s commitment to professionalism, ethical behavior and a supportive community culture. All employees share responsibility for fostering an environment where respect, integrity, acollaboration guide our work.
Accountability
FGCU expects all employees to uphold the highest standards of ethical conduct. Employees are individually responsible for understanding and complying with applicable laws, regulations, University policies and ethical expectations. This includes proactively seeking clarification when expectations are unclear, reporting concerns or violations in good faith and supporting a culture of integrity across the University. Failure to comply may result in corrective or disciplinary action, up to and including termination.
Responsibilities of All Employees:
• Know and comply with the laws, regulations, policies and procedures applicable to your work.
• Follow the University’s Code of Ethical Conduct and Ethics regulations.
• Be alert to situations that could lead or appear to lead to illegal, improper, or unethical behavior.
• Report concerns or suspected violations in good faith.
• Cooperate fully with internal reviews, audits, or investigations.
Responsibilities for Supervisors, Managers, Directors, Deans and Vice
Presidents:
• Lead by example and model ethical behavior.
• Promote integrity and encourage ethical decision-making within your teams.
• Create an environment where employees feel safe raising good-faith concerns.
• Clearly communicate that improper or unethical behavior is not tolerated.
• Ensure employees are aware of available University resources and reporting channels for seeking guidance or raising concerns.
• Prevent retaliation against anyone who reports concerns in good faith.
• Take prompt and appropriate corrective or disciplinary action when violations occur.
Compliance with Laws and Regulations
Under Section 1012.80, Florida Statutes, anyone who accepts employment at a state university is deemed to have consented to comply with the institution’s regulations, policies and applicable federal and state laws.
All members of the FGCU community must comply with federal, state and local laws in the performance of their university responsibilities. Each individual is responsible for staying informed about relevant legal obligations and for seeking guidance from supervisors or the Office of the General Counsel when clarification is needed.
Related Regulations and Policies:
• FGCU Regulations
• FGCU Policies
Privacy and Confidentiality
University employees are responsible for handling confidential information with care and in accordance with applicable laws and University policies. FGCU operates under Florida’s Government-in-the-Sunshine laws, which generally make most University-related records, including emails, accessible to the public. However, certain personal and official information about students, faculty, staff and donors, such as student records protected by FERPA, personnel data and donor information, must remain confidential.
Employees must protect sensitive information and share it only as authorized. When in doubt about what qualifies as confidential or which laws apply, employees should consult their supervisor or the Office of the General Counsel. Supervisors needing further clarification should also reach out to the Office of the General Counsel.
Training and Acknowledgment
Employees are expected to complete all mandatory trainings and participate in additional training and professional development that support their understanding of the University’s regulations, policies, ethical standards and Code of Ethical Conduct. These opportunities help ensure that all members of the FGCU community are equipped to make informed, ethical decisions and to uphold the University’s standards of integrity and professionalism.
Employees are responsible for applying the knowledge and guidance gained through training in their daily work. Participation in training and professional development reinforces a culture of ethical behavior, informed decisionmaking and adherence to University standards.
TRANSPARENCY AND RECORD KEEPING
FGCU is committed to transparency, integrity and accountability in all University operations. Employees must conduct their work in a manner that avoids any actual or perceived conflicts of interest or conflict of commitment.
Public Records
Employees must comply with Florida’s public records law and the University’s recordsretention requirements. Most documents created or received in the course of University business—including emails and text messages, whether on University or personal devices—are considered public records unless specifically exempt by law.
Public records requests must be handled in accordance with University procedures. Employees should promptly forward any request to the Office of the General Counsel rather than responding directly.
Record Retention and Preservation
University records must not be destroyed, deleted, or altered except in accordance with FGCU’s approved retention schedules. Employees share responsibility for creating, maintaining and safeguarding accurate University records as part of their role.
NON-DISCRIMINATION, ANTI-HARASSMENT, SEXUAL MISCONDUCT, TITLE IX AND CONSENSUAL RELATIONSHIPS
Florida Gulf Coast University is committed to providing a working and learning environment that is free from discrimination, harassment and sexual misconduct. In accordance with FGCU Regulation 1.003 and Policy 1.006, as well as related University policies, the university does not discriminate on the basis of race, color, religion, age, disability, sex, national origin, marital status, genetic predisposition, veteran status, pregnancy, or any other protected class as required by applicable state and federal law. Discrimination or harassment based on any protected classification is prohibited in all university programs, activities and employment practices.
Sexual misconduct, including sexual harassment, sexual assault, dating violence, domestic violence, stalking and other behaviors covered under Title IX, is not permitted. Employees are expected to treat all members of the University community with dignity, avoid conduct that may create a hostile or inequitable environment and seek guidance whenever they are unsure how to handle a situation. Most University employees, unless specifically designated as confidential resources, must promptly report concerns related to discrimination, harassment, or sexual misconduct to the Office of Institutional Ethics and Compliance so that the University can respond appropriately.
FGCU also requires employees to maintain professional boundaries consistent with the University’s Consensual Relationship Policy. Romantic or sexual relationships that involve a supervisory, evaluative, or advisory role, or that could reasonably create a conflict of interest, are not permitted and must be disclosed or avoided.
Retaliation against any individual who raises a concern or participates in a University process in good faith is not permitted. Employees who have questions about expectations, reporting requirements, or University procedures should contact the Office of Institutional Ethics and Compliance.
Related Regulations and Policies:
• Non-Discrimination, Anti-Harassment and Sexual Misconduct Regulation
• Sexual Harassment Under Title IX Regulation
• Non-Discrimination, Anti-Harassment and Sexual Misconduct Policy
• Sexual Harassment Under Title IX Policy
• Consensual Relationship Policy and Procedure Policy
• Disability Access and Reasonable Accommodation Policy
RESPONSIBLE CONDUCT IN RESEARCH
Responsible conduct in research encompasses any proprietary information, technical data, trade secrets, or nonpublic know-how, including cookbooks, recipes and methods, that may be subject to export controls. Modifications or enhancements to publicly available technology and software may create new items that could also fall under export control regulations if they are not intended for public dissemination. The extent to which research is subject to export controls is contingent upon various factors.
The Office of Research and Sponsored Programs strives to ensure that research is conducted to the highest standards of integrity and in compliance with the regulatory guidelines established by our university and the federal government. By upholding these standards, we aim to promote innovative thinking and foster honesty and independent thought among our students, graduates, faculty and staff. To facilitate this goal, we have established specific guidelines for conducting research. Please refer to the related policies below for further information.
The office is responsible for ensuring compliant and ethical conduct in research and oversees every phase of a sponsored project, from the initial proposal to the final audit.
All FGCU employees who oversee or provide administrative support for research activities must adhere to all relevant laws, regulations and policies. Should you have any questions or concerns, please do not hesitate to contact the Office of Research and Sponsored Programs for assistance.
Related Policy:
• Research Misconduct
INTELLECTUAL PROPERTY
Florida Gulf Coast University encourages its employees and students to undertake and/or assist with creative research endeavors and the development of new scholarship, works and inventions that stimulate learning and lead to the discovery of new knowledge.
Employees are expected to respect intellectual property rights and comply with FGCU’s Intellectual Property Policy.
Intellectual property includes but is not limited to inventions, discoveries, creative works, instructional materials, software, research data and other original works developed in the course of University employment or with the use of University resources.
Employee Responsibilities:
• Create, manage and use intellectual property ethically and responsibly.
• Follow University policies regarding ownership, disclosure and use of intellectual property.
• Respect the intellectual property rights of colleagues, students and external partners.
• Avoid unauthorized use, duplication, or distribution of copyrighted or proprietary materials.
• Direct questions about intellectual property or ownership to the Office of Research and Sponsored Programs, which administers FGCU’s intellectual property policy.
The Office of the General Counsel provides legal support related to intellectual property rights and agreements.
Related Policy:
• Intellectual Property
CONFLICT
OF INTEREST AND TIME COMMITMENT
Employees of FGCU have a primary obligation to the University. Outside employment or activities that conflict with this obligation, interfere with your ability to perform your University duties, or create the appearance of a conflict of interest are prohibited.
Definitions
• Outside Activity(es): Includes, but is not limited to, any private practice, private consulting, additional teaching, board activities, or research employment or other activity, within or outside the University, compensated or uncompensated, which is not part of the employee’s assigned duties for their primary position at FGCU, including secondary or overload duties and for which the University has provided no compensation. Outside Activities generally do not include social, recreational, fraternal, or related activities such as volunteering for religious or charitable organizations.
• Conflict of Interest: Professional, financial, or personal activities or relationships that compromise, or have the appearance of compromising, an employee’s professional loyalty and responsibility to any conflict between the private interests of the employee and the public duty or interests of the University, the Board of Trustees, or the State of Florida, including those conflicts of interest specified under Florida Statutes; or any activity whether paid or unpaid which interferes with the full performance of the employee’s professional or institutional responsibilities or obligations, including Conflicts of Time Commitment.
• Conflict of Time Commitment: Arises when an employee undertakes a role, compensated or uncompensated, inside or outside of the University that interferes, appears to interfere, or has the potential to interfere with the employee’s time and ability to perform core job responsibilities of their primary position and commitments to the University.
General Expectations
• You must carry out your University duties in a full and competent manner without letting outside employment or activities reduce your commitment to FGCU.
• You must not claim to represent the University, or use the University’s name, logo, facilities, equipment, services, or resources for your outside employment or activities without prior written approval.
• You must comply with the Code of Ethics for Public Officers and Employees (Part III, Chapter 112, Florida Statutes).
Examples of Activities That May Require Disclosure
To help employees understand which types of activities must be disclosed, the following categories require reporting and approval.
• Florida Conflicts of Interest Standards of Conduct
• Government Participation
• Textbook and Similar Instructional Materials
• Consensual Relationships
• Sponsored Travel
• Activities with a Foreign Entity
• Board Participation
• Outside Activities and Outside Employment
• Nepotism
• Gifts and Entertainment Received
• Sponsored Research or Extramural Proposals
• Other Miscellaneous Activities
Approval & Reporting Requirements
• Before engaging in any outside employment or outside activity, you must obtain approval through the University’s prescribed conflict management system by submitting the Conflict of Interest Disclosure Form. The information you provide will be reviewed to determine whether the proposed activity presents a Conflict of Interest or a Conflict of Time Commitment.
• When approving such activities, the University will consider whether the proposed outside activity:
• Would reasonably and materially interfere with your University duties (e.g., work hours, quality or timeliness)
• Would conflict with the standards of conduct required of your position
• Would be contrary to the goals or mission of the University
At hiring you must attest to any current outside employment or activity and your understanding of the reporting requirements. Annually thereafter, you must submita disclosure form and obtain approval for any ongoing outside employment/activity. Authorization is granted for a defined period (typically not exceeding one year) and must be renewed each fiscal year.
Nepotism
Employees must avoid situations where personal or family relationships could improperly influence employment decisions or create a conflict of interest. In accordance with the University’s Nepotism Regulation, employees may not hire, supervise, evaluate, promote, or make compensation or assignment decisions for a Related Person. A Related Person includes a family member or any individual with whom the employee has a romantic or intimate relationship.
Employees must disclose any relationship that may present the appearance of favoritism or a conflict of interest so the University can determine whether a management plan or other action is necessary. Exceptions may be considered only through the formal waiver process provided in the University’s Nepotism Regulation.
Employees who have questions about whether a relationship constitutes nepotism should contact the Office of Institutional Ethics and Compliance for guidance.
Disclosure & Resolution
If a proposed outside activity is determined to create a conflict of interest or materially interfere with your University duties, you will be notified in writing. You must work with the University to resolve the conflict before proceeding.
Related Regulation and Policy:
• Outside Activities
• Nepotism
GIFTS, HONORARIA AND BENEFITS
As employees of Florida Gulf Coast University, we are subject to Florida Statutes Chapter 112, Part III, the Code of Ethics for Public Officers and Employees. These laws ensure that public employees act independently and impartially and do not use their positions for private gain. Employees must avoid any situation where gifts, benefits, or other items of value could create, or appear to create, undue influence or preferential treatment.
Prohibition on Gifts and Benefits
FGCU employees may not solicit or accept anything of value, including gifts, honoraria, or benefits, if:
• Carrying out University business.
• The item is offered to secure special privileges or favorable treatment for yourself or others.
• You know, or reasonably should know, that it is being given to influence a decision or action.
Additionally, your spouse or minor child may not solicit or accept anything of value on your behalf under circumstances that would be prohibited for you.
What Is a Gift?
Under Florida law, a “gift” is broadly defined as anything of value that you receive, or that is given on your behalf, for which you do not provide equal or greater consideration within 90 days.
Examples of gifts include:
• Membership dues
• Food or beverages
• Plants, flowers, or floral arrangements
• Transportation or lodging
• Admission fees, tickets, or event access
• Services normally provided for a fee
• Property or the use of property, whether tangible or intangible
• Preferential rates or terms not available to the public
• Forgiveness of debt
Employees must disclose gifts that may create a conflict of interest or the appearance of undue influence by submitting the Conflict of Interest Disclosure Form. When in doubt about whether a gift should be disclosed, contact the Office of Institutional Ethics and Compliance for guidance.
Honoraria
An honorarium is a payment of money or anything of value, directly or indirectly, provided to an employee or to another person on their behalf as compensation for a speech, oral presentation, or written work other than a book that is published or intended to be published.
An honorarium does not include:
• Payment for legitimate outside employment.
• Ordinary compensation for work related to your University duties.
• Payment or reimbursement for reasonable transportation, lodging, registration fees, or food and beverages for you and your spouse related to the honorarium event.
Small or Promotional Items
Employees may generally accept promotional items of nominal value, such as pens, calendars, or coffee mugs, if permitted by law. When deciding whether a small item is acceptable, consider its value, whether public disclosure might give the impression that it was intended to influence a University decision and whether a reasonable person could perceive a conflict.
If you know, or reasonably should know, that an item is being offered to influence you, do not accept it. When in doubt, contact the Office of Institutional Ethicsand Compliance.
Related Policies:
• Gifts and Honoraria
USE OF UNIVERSITY RESOURCES
University resources including funds, facilities, equipment, technology, vehicles, data and work time are public assets provided for the purpose of supporting FGCU’s mission of teaching, research and service. Employees are expected to use these resources responsibly, efficiently and only for authorized University business. Limited incidental personal use of common resources such as email or office equipment may be permissible when it does not interfere with job duties, create additional costs, or violate University policy.
Employees may not use University resources for personal financial gain, political activity, or other non-University purposes. All use must comply with Florida law, the Florida Code of Ethics for Public Officers and Employees and FGCU policies on technology acceptable use, purchasing, travel, records management and branding. Any suspected misuse of resources should be reported to a supervisor, the Office of Institutional Ethics and Compliance, Internal Audit, or through the EthicsPoint hotline. Good-faith reports are protected from retaliation.
IT COMPLIANCE
Email, Internet and Information Systems
You must use University email and internet accounts responsibly and protect the security of our information systems.
FGCU’s information technology systems are a key component of our University operations and are provided for authorized business purposes. Learn more about Technology Resources for Students, Faculty and Staff.
Your use of these systems must comply with our Acceptable Use Policy and Email Policy.
• Technology Resources Policy
• University Email Policy
You may engage in reasonable incidental personal use of phone, email and the internet as long as such usage does not:
• Consume large amounts of time and resources;
• Interfere with your work performance or that of others;
• Involve illegal, sexually explicit, discriminatory or otherwise inappropriate material;
• Relate to outside business interests; and
• Violate any University policy or regulation.
To safeguard FGCU information systems, you should never:
• Share your University system passwords with anyone;
• Leave laptops or other mobile devices unattended while traveling or in an exposed location where they can be stolen; or
• Download unauthorized or unlicensed software on University computers.
Travel abroad with University Technology Resources requires University approval and compliance with travel policy guidelines (check University Help Desk on loaner laptop availability).
If you suspect a data breach or become aware of any situation in which data has been compromised, including the loss or theft of a laptop or handheld device, immediately report the situation to the University Help Desk at (239) 590-1188 or helpdesk@fgcu.edu
Related Policies:
• International Travel Policy
Working With Restricted Data
Restricted data is University data that is highly confidential and covered under state or federal privacy law. If you are unsure what is restricted data, visit the ITS webpage for more details, including a link to the University’s Restricted Data Policy:
• Restricted Data Examples
• Restricted Data Policy
Follow these guidelines to protect restricted data from accidental loss or disclosure.
• How do I Handle Restricted Data at Work?
• How do I Handle Restricted Data at Home?
• How Do I Dispose of Equipment That Has Stored Restricted Data?
If you require further information including encrypting files or email contact the University Help Desk at (239) 590-1188, refer to the ITS Knowledge Base or Email Help Desk
Use Of Social Media
Social media platforms are powerful tools for communication, allowing the University to share news, promote events and engage directly with the FGCU community and the public. The use of social media requires care, professionalism and alignment with the University’s values and brand standards to ensure effective and responsible communication.
Employees and students who manage or contribute to Universityaffiliated accounts serve as representatives of FGCU. As such, all content shared through these channels should reflect the University’s mission, uphold its reputation and adhere to institutional brand and communication standards.
All University-affiliated accounts must follow FGCU’s Social Media Policy, which outlines expectations for responsible use, management and content creation to ensure consistency, accuracy and professionalism across all platforms.
Related Policies:
• Social Media Policy
SUSTAINABILITY
Environmental sustainability is a shared responsibility and an essential part of FGCU’s mission. Every employee contributes to protecting our natural resources, conserving energy, reducing waste and supporting a healthy and resilient campus environment.
Employees are expected to:
• Practice sustainable operations, including reducing waste, recycling and using reusable products.
• Prevent stormwater pollution and protect water quality by properly managing waste and reporting spills or illegal dumping.
• Conserve energy and resources by turning off lights and electronics, limiting printing and making environmentally conscious purchasing decisions.
• Respect and protect campus wildlife, reporting injured or distressed animals when necessary.
• Support safe, healthy campus environments by minimizing toxic chemicals and managing hazardous materials responsibly.
• Consider environmental impacts when making decisions, including procurement, event planning and operational practices.
FGCU’s colors — emerald green and cobalt blue — reflect our connection to the earth and water that sustain life. Sustainability is woven into our identity as a university and guides our commitment to responsible stewardship
ACADEMIC INTEGRITY AND ACADEMIC FREEDOM
Florida Gulf Coast University is committed to maintaining an environment where teaching, learning, scholarship and creative activity are conducted ethically and responsibly. Academic integrity is central to the University’s mission and is expected of all employees engaged in academic work.
Academic Freedom
Academic freedom allows employees to discuss all relevant matters in the classroom, to explore all avenues of scholarship, research and creative expression, to speak freely on all matters of University governance and to speak, write, or act as an individual, all without institutional discipline or restraint.
Academic Responsibility
On the part of an employee, Academic Responsibility implies the honest performance of academic duties and obligations, the commitment to support the responsible exercise of freedom by others and the candor to make it clear that the individual, while he or she may be freely identified as an employee of the University, is not speaking as a representative of the University in matters of public interest.
Source: Article 5, Academic Freedom and Responsibility, Collective Bargaining Agreement. Article on Defining Academic Freedom
Outside of these principles, employees engaged in academic activities are expected to:
• Uphold ethical standards in teaching, research and creative work.
• Ensure accuracy, honesty and professionalism in academic obligations.
• Respect the academic freedom and intellectual contributions of others.
• Follow applicable University regulations, policies and legal requirements related to academic conduct.
ATHLETICS COMPLIANCE AND CONDUCT
Florida Gulf Coast University (FGCU) is committed to conducting its intercollegiate athletics programs with the highest standards of integrity and in full compliance with all applicable National Collegiate Athletic Association (NCAA), Atlantic Sun Conference (ASUN), Coastal Collegiate Sports Association (CCSA) and University rules and regulations.
FGCU monitors its athletic programs to ensure compliance, identify potential violations and report concerns to the appropriate governing bodies. In any instance in which compliance issues arise, FGCU will cooperate fully with the NCAA, ASUN, CCSA and any other relevant authority and will take appropriate corrective or cooperative actions.
Student-athletes, coaches, Athletics Department staff and any individuals or groups representing FGCU’s athletics interests are expected to comply with all NCAA and conference rules. Employees who interact with student-athletes, prospective student-athletes, or Athletics Department personnel must understand and adhere to all applicable requirements.
Employees are also expected to fully cooperate with Athletics Compliance inquiries or investigations. Any potential NCAA rule violations or concerns must be reported promptly to the Athletics Compliance Office.
REPORTING, WHISTLEBLOWING AND RETALIATION
FGCU depends on employees to speak up when something does not seem right. If you have a concern, cannot find an answer in this Code of Ethical Conduct, or are unsure how to interpret a policy or expectation, you are encouraged to seek guidance. If you become aware of conduct that may violate the University’s mission, vision, core values, this Code of Ethical Conduct, regulations or policies, or state or federal laws, you are expected to report the concern so it can be addressed promptly and appropriately.
Employees have several resources to obtain assistance or make a report:
• Supervisor or Manager – First point of contact for most workplace concerns
• Office of Institutional Ethics and Compliance – Reports of discrimination, harassment, or sexual misconduct
• Office of Internal Audit – Whistleblower protection and allegations involving fraud, waste, or abuse.
• Human Resources – Employment policies, workplace issues and employee relations
• Office of the General Counsel – Guidance on University regulations, policies and legal requirements
• University Ombuds – Informal and confidential assistance with conflict resolution
• Chief Ethics and Compliance Officer – Ethics and compliance concerns, including potential violations of University policies, regulations, or applicable laws.
Employees may raise concerns through these channels and may request confidentiality to the extent permitted by law.
In addition to internal resources, employees may report concerns or suspected violations through the University’s EthicsPoint Hotline, which allows for confidential or anonymous reporting. The hotline is operated by NAVEX Global, a third-party provider and is available 24 hours a day, 365 days a year.
You may submit a report by:
• Calling (844) 989-2950
• Submitting an online report through the EthicsPoint portal
How the EthicsPoint Hotline Works
When you submit a report:
• A trained specialist collects information about your concern.
• The report is forwarded to the Chief Ethics and Compliance Officer.
• The OIEC reviews and, if necessary, investigates the matter.
• You may choose to remain anonymous or request confidentiality to the extent permitted by law.
• You will receive a report key and password to provide additional information or to follow up on the status of your report.
The Hotline must be used responsibly. Intentionally submitting false or misleading information is not protected and may result in disciplinary action.
If you encounter an active emergency or someone’s health, safety, or property is at immediate risk, call 911 or contact University Police.
Protection from Retaliation
FGCU strictly prohibits retaliation against any individual who makes a good-faith report of a concern, seeks guidance about a potential issue, or participates in an investigation. Retaliation includes adverse actions such as intimidation, threats, harassment, or negative employment consequences directed at someone for fulfilling their ethical or legal reporting responsibilities.
Any suspected retaliation should be reported immediately through one of the resources listed above.
What Is a Good-Faith Report?
A good-faith report is made with an honest belief that the information shared is truthful based on what the employee knows at the time. Good-faith reports may involve concerns, suspected violations, or uncertainty about how a policy applies in a particular situation.
Reports made with knowingly false information, intentional misrepresentation, or a willful disregard for the facts are not considered good-faith reports and may result in disciplinary action.
What Is Retaliation?
Retaliation is any adverse action, or threat of adverse action, taken against an individual for reporting a concern in good faith, seeking guidance about a potential issue, or participating in an investigation.
Adverse actions may include changes in job duties, demotion, termination, reassignment to less desirable tasks, intimidation, threats, or other behaviors that would discourage a reasonable person from raising concerns.
FGCU strictly prohibits retaliation in any form. Any suspected retaliation should be reported immediately.
CLERY ACT COMPLIANCE AND CAMPUS SAFETY REPORTING
FGCU complies with the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, which requires the University to maintain accurate crime statistics, publish an Annual Security and Fire Safety Report and issue safety alerts when certain crimes or emergencies pose a threat to the campus community. The University Police Department coordinates these responsibilities on behalf of the institution.
Some employees are designated as Campus Security Authorities because of the nature of their roles. Campus Security Authorities must promptly report Clery reportable crimes brought to their attention so the University can assess safety risks, support those involved and meet federal reporting obligations. Even employees who are not Campus Security Authorities are encouraged to support campus safety by reporting suspicious or criminal activity and directing individuals to appropriate University resources.
FGCU may issue Timely Warnings or Emergency Notifications to alert the community to significant threats. Employees are expected to follow the instructions in these communications, encourage compliance among students and colleagues and contact the University Police Department whenever they become aware of behavior that may endanger the campus community. Employees must also report any suspected hazing, as hazing is prohibited by Florida law and University policy and may constitute a Clery reportable offense.
Employees who have questions about Clery responsibilities, Campus Security Authority designations, or campus safety procedures should contact the University Police Department.
HEALTH, SAFETY AND ENVIRONMENTAL RESPONSIBILITY
Florida Gulf Coast University is committed to fostering a safe, healthy and sustainable environment for all members of our community. Employees are expected to conduct themselves in a manner that supports the University’s safety standards, environmental stewardship goals and overall well-being.
Employees must follow all applicable federal, state and local laws; University health, safety and environmental procedures; and any required training. FGCU is committed to maintaining proper licenses, permits and approvals related to environmental and workplace safety and to using appropriate procedures and controls when handling radioactive, toxic, hazardous, or biohazardous materials and waste.
Each employee plays an important role in minimizing waste, preventing pollution and protecting the natural environment. Employees are expected to use University resources responsibly, help maintain clean and safe workspaces and model healthy and safe behaviors.
DRUG-FREE, ALCOHOL-FREE AND SUBSTANCE-FREE CAMPUS
FGCU is dedicated to maintaining a workplace free from the use, possession and distribution of illegal drugs, controlled substances and the unlawful use of alcohol. To ensure a safe and productive environment:
• Employees may not be under the influence of alcohol, illegal drugs, or controlled substances while on campus or performing work duties.
• The manufacture, distribution, dispensing, possession, or use of illegal drugs or controlled substances is strictly prohibited on University premises or as part of any University-sponsored activity.
• Alcohol possession or consumption must comply with the University’s policies governing the service and use of alcoholic beverages at University functions.
Employees are encouraged to speak up and share any concerns if they:
• Are asked to perform a task that may be unsafe
• Are asked to perform a task for which they feel untrained or unprepared
• Suspect that a golf cart, vehicle, or piece of equipment is not functioning properly or safely
• Notice a potentially unsafe condition or hazard
• Observe or are informed of any discharge of substances (other than rainwater) into campus storm drains, ponds, catch basins, or grounds
Employees should promptly report unsafe conditions, environmental hazards, or health and safety concerns to the appropriate University office.
The abuse of alcohol or controlled substances impairs judgment and performance, creates an unsafe work environment and undermines our responsibility as role models for students.
Related Policies:
• FGCU Drug Free Environment Policy
• FGCU Possession, Service, or Consumption of Alcoholic Beverages at University Functions Policy
TOBACCO-FREE AND SMOKE-FREE CAMPUS
Florida Gulf Coast University is a smoke-free and tobacco-free campus. To protect the health of our community and support the University’s environmental and wellness initiatives:
• The use of all tobacco products, smoking devices and vaping/e-cigarette devices is prohibited anywhere on University property.
• Employees are expected to comply with this policy at all times and to help maintain a clean and healthy campus environment.
• The University provides resources and programs to assist employees who wish to reduce or discontinue tobacco use.
The abuse of alcohol or controlled substances impairs judgment and performance, creates an unsafe work environment and undermines our responsibility as role models for students.
Related Policy:
• Smoke-Free and Tobacco-Free Campus Policy
WEAPONS AND CAMPUS SAFETY
To ensure the safety and security of the University community, FGCU prohibits the possession, use, or storage of weapons on University property or at University-sponsored events. Weapons include, but are not limited to, firearms, ammunition, knives (other than approved utility tools), explosives and other dangerous devices.
Exceptions may apply only to:
• Law enforcement officers acting within the scope of their duties;
• Participants in authorized academic programs or activities (e.g., ROTC);
• Other limited circumstances as permitted by Florida law.
All employees must comply with applicable Florida Statutes, including sections 790.115 and 790.06. Employees licensed to carry concealed weapons or firearms are not permitted to possess or carry them on University property except as expressly allowed by law.
Violations may result in disciplinary action and may also carry legal consequences.
Related Regulation:
• Possession of Firearms and Weapons on University Property
REVIEW & AMENDMENT
The Employee Code of Ethical Conduct will be reviewed on a regular basis to ensure that it remains accurate, relevant and reflective of the University’s mission, values and applicable legal requirements.
The Office of Institutional Ethics and Compliance, in collaboration with the Office of the General Counsel and other key university stakeholders, is responsible for coordinating periodic reviews and recommending updates as needed.
Proposed amendments may be initiated by the Office of Institutional Ethics and Compliance, the Office of the General Counsel, or other administrative
units and must be reviewed through the appropriate university governance and approval processes. Substantive revisions are submitted to University leadership and, when required, to the Board of Trustees for approval.
The most current version of the Employee Code of Ethical Conduct is maintained on the University’s website. Employees are responsible for reviewing and adhering to the latest version of the Code. This Code is not a contract and does not create any entitlement to continued employment.
CONTACT INFORMATION
While this Code provides guidance, it cannot anticipate every situation that may arise.. Employees are encouraged to seek guidance from the Office of Institutional Ethics and Compliance whenever questions arise about expectations, policies, or appropriate conduct.
References to laws, regulations and University policies are provided throughout this Code for informational purposes. These laws, regulations and policies may be updated from time to time and employees are responsible for complying with the most current versions, even if this Code has not yet been updated to reflect those changes.
Florida Gulf Coast University
Office of Institutional Ethics and Compliance
10501 FGCU Boulevard South Fort Myers, FL 33965
Telephone: (239) 745-4366
Email: oiec@fgcu.edu
Office of Institutional Ethics & Compliance (OIEC)
