Lakeland College Employee & College Member Code of Conduct

Policy Name: Employee & College Member Code of Conduct

Policy Number: HR 2.04-1

Policy Owner: President & CEO

Policy Lead: Director, Human Resources

Policy Authority and Approval Date: September 1, 2019

Leadership Committee: April 30, 2019

A. Policy Statement Lakeland College (the “College�) strives to promote trust and respect among members of the college community. In order to promote a positive work and learning environment, Lakeland College expects members of the college community, including its employees, to adhere to the values of integrity, credibility, professionalism and honesty.

B. Scope Statement This Code applies to all members of the college community, except members of the Board of Governors and President and CEO, who are subject to the code of conduct contained in the Lakeland College Board of Governors Policy Handbook.

C. Definitions Conflict of Interest: a situation in which an employee has or could be perceived to have a private or personal interest that could influence the objective exercise of their responsibilities as an employee; or a situation in which an employee directly or indirectly competes with or aids another to compete with Lakeland College, or engages in a business or practice contrary to the interests, goals, objectives, or business of Lakeland College.

Members of the College Community: includes, but is not limited to, employees, visitors, volunteers, consultants and service and supply contractors and their employees while they are engaged in activities related to their contracts with Lakeland College. Members of the Board of Governors, including the President and CEO, are not considered a member of the college community for the purpose of this Code.

D. Procedure (July 12, 2018) Expectations of Members of the College Community 1. Members of the college community are expected to demonstrate courtesy, respect, patience, and helpfulness towards others, and work to resolve conflicts arising with other members.

2. Members of the college community must conduct themselves, and encourage others to conduct themselves, in a manner that values the personal dignity of individuals and is in compliance with all Page 1 of 6

government legislation, including the Canadian Charter of Rights and Freedoms and the Alberta Human Rights Act. 3. Members of the college community must act impartial, honest, and responsible in their relations with others, when acting as a member of the college community, whatever their area of activity.

4. Members of the college community must maintain the confidentiality of information entrusted to them by the College or its stakeholders, and only collect, use, or disclose such information as is required in the fulfillment of their duties, by College policies and procedures, the Freedom of Information and Protection of Privacy Act, and any other applicable legislation: 

See also 8.73 Records Retention, 8.78 Access to Information and Protection of Privacy, 8.79 Handling Information Requests, 9.58 Password Policy.

5. Members of the college community must not engage in sexual and/or inappropriate relationships with other members of the college community over whom they have influence or could be perceived to have influence. Where such a relationship exists, member(s) must follow the conflict of interest procedure specified in this Code.

6. Lakeland College considers environmental protection to be an essential and integral element in conducting its business. The College aims to ensure that its activities and operations, at a minimum, comply with all environmental laws in the jurisdictions in which it operates. 

See also 6.59 Energy Management.

7. Lakeland College has a role in contributing to a healthy and safe workplace and observes and adheres to a number of related internal policies and procedures: 

See also 8.51.1 First Aid Regulations, 8.51.2 Contractor Health and Safety, 10.1 Smoking on College Property.

EMPLOYMENT EXPECTATIONS General Obligations 1. Employees are prohibited from acting in self-interest or furthering their private interests by virtue of their position or through the carrying out of their duties.

2. Employees will establish and maintain appropriate professional boundaries with students and other members of the college community. Employees or others who are unsure of what constitutes professional boundaries should consult with their supervisor or Human Resources. 

See also 2.04-2 Harassment/Discrimination/Workplace Violence.

Conflicts of Interest 3. Employees should avoid engaging in any activity considered to be a conflict of interest. Employees should check with the applicable Dean/Director or the applicable Vice-President if they are unsure of what constitutes a conflict of interest.

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

The College considers, in particular, involvement in alternate employment or other appointments, business, or undertakings other than the employment with the College to be a conflict of interest to be reported and assessed in accordance with this Code.

4. An employee with a real or apparent conflict of interest must immediately: a. Self-report the conflict of interest to the applicable Dean/Director or the applicable Vice-President; b. End or resolve the conflict of interest or seek a determination the conflict is manageable; and c. Take reasonable steps to protect themselves and the interests of the College.

5. An employee with a real or apparent conflict of interest that will not be immediately ended or resolved must request that the College review the conflict of interest and make a determination as to whether the conflict is a manageable conflict. a. A request is to be made to the Human Resources department and must specify: i.

The nature of the conflict of interest;

ii. The actions the employee will take to ensure the conflict does not prejudice their ongoing employment responsibilities with the College; and iii. If the conflict relates to alternate employment, appointments, business, or undertakings other than the employment with the College, the contact information of persons involved with the other activity that the College may contact if necessary to determine whether any conflict will be manageable or not. b. The Human Resources department may involve an employee’s immediate supervisor, the President and CEO, or any other appropriate parties in investigating whether the conflict of interest is manageable. The Human Resources department may also delegate the investigation and determination to any party it deems appropriate. c. The College, through the Human Resources department or the other delegated party, will make a written determination within a reasonable time from the receipt of the request as to whether or not the conflict of interest is manageable: i. If the conflict of interest is determined to be unmanageable, the employee must end or resolve the conflict or resign from their employment with the College. ii. If the conflict of interest is determined to be a manageable conflict, it is the obligation of the employee to ensure the conflict remains manageable and to notify the College of any material change in circumstances.

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6. Supervisors will ensure that their employees have read and have signed off on this Code. Signed Codes will be forwarded to the Human Resources office and kept on file. A review and re-submission of the signed form will occur at regular intervals. Former employees who are rehired will be required to sign the form upon commencement.

Gifts and Event Invitations 1. Employees shall not accept any gifts, entertainment, hospitality or other special considerations outside the scope of accepted business courtesies if acceptance of that gift could create an actual or apparent conflict of interest. Employees must use their discretion and recognize that while a gift or invitation may be offered with the expectation of receiving nothing in a return, acceptance may still create a perception of a conflict of interest. Where such a perception exists, acceptance must be avoided or the perception must be resolved prior to acceptance.

2. The Code is not intended to prohibit the acceptance of every gift or event invitation, only those where acceptance may create an actual or apparent conflict of interest. Situations which are not expected to create a conflict of interest are: a.

The normal exchange of gifts between friends where unrelated to any position or duties performed for the College;

b.

Reasonable gifts given as part of a cultural practice, tradition, or in recognition of participation;

c.

The receipt of nominal or token gifts received as part of normal protocol or social expectations; and

d.

Acceptance and attending an event where: i.

Many College stakeholders are invited;

ii. The event is open and free to the public; iii. The employee pays for food, beverage, and all other costs of attendance; or iv. Attendance is for the purposes of professional development or advancing the College’s interests or public profile.

3. No employee may accept, without special approval: a. b. c.

Any single gift with a cash value in excess of $200; Any event (e.g. Conference, Sporting, Gala) invitation with a cash value, including food, beverage, travel and/or accommodation, in excess of $400; or All combinations of gifts and event invitations received from a single source, within one year, with a total cash value in excess of $400.

4. No employee shall accept a gift of cash or cash equivalents.

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5. If an employee accepts a gift with a maximum cash value in excess of any stipulated maximum, the gift will become the property of the College.

6. If the valuation of any gift or event is disputed, the value will be as determined in the sole discretion of the President.

7. An employee, who is uncertain if acceptance of a gift or event invitation is appropriate, or who is offered a gift or invited to an event valued in excess of a maximum cash value, may contact the applicable Vice-President or the President for direction or to seek special approval.

Property of the College 1. Any confidential information used or acquired by an employee during the course of their employment is the property of Lakeland College and is not to be shared or disseminated without permission. Upon leaving Lakeland College, employees must return any confidential information in their possession to their supervisor.

2. Preserving and safeguarding college property is the responsibility of every employee.

3. Equipment, materials, supplies and services that are the property of the College must be used towards the interests and benefit of Lakeland College.

Non-Compliance and Discipline 1. Members of the college community have a responsibility to report any circumstances or actions involving an employee that violate or appear to violate this Code. Such reports or complaints are confidential and individuals will not be subject to reprisal for raising a concern or making a report in good faith. Reports by an employee can be made to an applicable Dean/Director or Vice-President or the President. Non-employees may report to the Human Resources department. 

See also 8.85-1 Whistleblower Procedure, 3.97 Fraud Procedure

2. Upon receiving a report or complaint, the recipient of the complaint will meet with the employee(s) involved and discuss the concerns with the intent of trying to resolve the situation informally.

3. If the situation cannot be resolved informally, the recipient of the complaint will report the matter, any steps taken, and any responses gathered, to the Human Resources department. The Human Resources department will conduct a further investigation, if it determines any further investigation is necessary, and then make a determination. The Human Resources department may also delegate the investigation and determination to any party it deems appropriate.

4. If the report or complaint is substantiated, and the employee is determined by the Human Resources department or the other delegated party to have contravened this Code, the employee may be subject to a range of disciplinary measures ranging from a verbal reprimand to dismissal from employment with the College. Any disciplinary decision will take into account the nature and effect of the violation and will be determined based on the circumstances and in accordance with any existing contractual or collective agreements. The principles of progressive discipline will be applied but the College may, if the circumstances warrant, skip steps in the progression of discipline based on the severity of the contravention.

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NOTICE PERIOD & AMENDMENTS 1. This Code will be submitted to the Ethics Commissioner for review pursuant to section 23.922 of the Conflicts of Interest Act. 2. Providing approval has been received from the Ethics Commissioner in accordance with the Conflicts of Interest Act, this Code will be made public on or before April 30, 2019.

3. The period from the date the Code is made public, until August 31, 2019 will be the public notice period.

4. This Code will be implemented on September 1, 2019.

5. The College reserves the right to amend this Code at any time, including but not limited to: On the advice or demand of the Office of the Ethics Commissioner; or Where required to ensure compliance with any changes to the Conflicts of Interest Act, the Post-Secondary Learning Act, or any other applicable legislation or order in council.

6. Any amendment or replacement of this Code will be submitted to the Ethics Commissioner for approval in a manner pursuant to section 23.923(2) of the Conflicts of Interest Act and any other applicable provisions or legislation.

ADMINISTRATIVE 1. If there are any doubts as to whether a course of action is proper, or about the application or interpretation of this Code, or of any legal requirement, members of the college community are advised to discuss the matter with their immediate supervisor, if applicable, or the Human Resources department. If further guidance is required, a member of the Human Resources department can provide advice.

2. No code of conduct can offer a complete guide to cover all possible situations that might be encountered. This Code is intended to provide members of the college community with an overview of those obligations of particular importance.

E. Relevant Legislation Province of Alberta, Conflicts of Interest Act - http://www.qp.alberta.ca/documents/Acts/C23.pdf F. Related Forms/Documents Code of Conduct Acknowledgement Form

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