All-College PoliciesGray Pages

We are pleased to share with you our All-College Policies. These policies were developed as a guide for members of the campus community.

As members of the College, we play an extremely important role in supporting the goals of the institution. These policies are not intended to be an implied or expressed contract but an informative document. The College may add to the policies or revoke or modify them from time to time. Administration will try to keep this material current, but there may be times when policy will change before this handbook can be revised.

The academic excellence of Gustavus comes about because of a concerted effort on the part of students, faculty and staff to maintain the highest standards and goals in all of our activities. Together we can nourish a campus environment that is respectful to all and is one that ensures that our commitment to the search for excellence will continue long into the future.

Sincerely,
The Office of the Provost

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Scope: Consistent with our Shared Governance Principles, this procedure sets forth the framework for review, consideration, and adoption of policies applicable to the entire College community (All-College Policies). It specifically deals with All-College Policies proposed by the Faculty (through the Faculty Senate), Administration (through the President), or Board of Trustees (through the Board Chair).

Academic Policies: Proposals for new academic policies for the Faculty Manual and Faculty Handbook are administered through the Faculty Senate and approved by the full faculty. The Board of Trustees must approve any changes to the Faculty Manual. Academic policies which affect the Faculty Manual are within the scope of this framework.

Non-Academic All-College Policies: Proposals for new non-academic All-College Policies will generally originate with the Administration through the President. However, such policies may originate with the Faculty (through the Faculty Senate) or the Board of Trustees (through the Board Chair). 

Consultation Process: Proposed non-academic All-College Policies and academic policies to be contained within the Faculty Manual should be shared with the Vice President for Equity and Inclusion to ensure alignment of the policy with inclusion and equity efforts and the Shared Governance Committee. Both bodies will review and comment prior to consideration for policy approval and adoption. All comments received should be thoughtfully considered by the proponent of the policy. 

If the faculty representatives on the Shared Governance Committee deem that the proposed policy substantially impacts the compensation, benefits, responsibilities, or rights that are specific to faculty (as defined in the Faculty Manual and/or Faculty Handbook), the proposed policy will be forwarded for review and endorsement by the Faculty Senate. 

Once endorsed by the Faculty Senate (if necessary), the proposed policy shall be finally reviewed and adopted by the Administration (i.e., President’s Cabinet) and Board of Trustees (as necessary). If the policy is not approved, suggested revisions and/or concerns will be shared with the policy proponent who may choose to re-initiate the consultation process. 

In the event that anything in this policy conflicts with state or federal law, the state or federal law takes precedence.

Interim Policies: Under extraordinary circumstances, a situation may arise in which an All-College Policy must be established, and the time required to act does not accommodate the process outlined above. In these instances, the Administration, through the President or Board of Trustees, may adopt an interim policy with immediate effect. Such interim policies shall not extend for more than one-year and shall, immediately after adoption be subject to the process described herein for adoption as an All-College Policy.

Communication: All policies adopted through this process shall be communicated broadly to the campus community and published as appropriate for the greatest awareness.

Approved by the Gustavus Adolphus College Board of Trustees: February 11, 2022.

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Purpose of Policy

This policy pertains to the decision-making process prior to the potential canceling or delaying of college-related activities due to threat of inclement weather or other catastrophic event. It also addresses cancellation of ongoing college activities when a potential threat is anticipated or discovered.

Owner(s)

CFO and VP for Finance and Treasurer (co-owner), Provost (co-owner), VP for Student Life and Dean of Students (backup), Director of Campus Safety, Director of Physical Plant, and Director of Environmental Health, Safety and Risk Management.

Scope

Over 2100 students reside in residential facilities on campus at Gustavus Adolphus College. Therefore, the campus is de facto always “open” even when certain extreme circumstances may force the College administration to cancel or delay College activities such as:

• Teaching conducted by faculty
• Work conducted by staff
• Other activities such as worship services, sporting events, concerts, lectures, performing arts, and/or civic events

This policy applies to all on-campus events, including those that are not included on the on-campus calendar and those arranged by on- and off-campus entities.

Process

Information Gathering Phase¹: On-campus Campus Safety Staff will initiate the process of considering campus conditions. On-campus Physical Plant and Campus Safety staff shall report details of current campus environmental conditions to their respective department leaders (Director of Physical Plant and Campus Safety Director and/or Assistant Directors). Department leaders shall discuss conditions and communicate a common recommendation to the Director of Environmental Health, Safety and Risk Management. The Director of Environmental Health, Safety and Risk Management shall take this on-campus recommendation, along with information from external sources (i.e., weather radar, road conditions, etc.) and make a recommendation to the CFO and Provost.²

Decision Making Phase: The CFO and Provost will consider the final recommendation of the Director of Environmental Health, Safety and Risk Management and discuss the recommendation with the VP for Student Life and Dean of Students^2,3. In the event of a cancellation, delay, or closing recommendation, the CFO and Provost shall take into account mandatory functions on campus, weather forecast and DOT recommendations. The CFO or Provost will discuss the deliberations with the President prior to issuing a final decision.

Dissemination of Information Phase: Once a decision has been made, the CFO or Provost will notify the VP for Marketing and Communication, including information garnered from the Associate VP of Auxiliary Services, Library Chair, and Athletics Director about the Marketplace, Lund Center, and Library hours and others as needed. The Office of Marketing and Communications shall broadcast the final decision within the Gustavus community and to other appropriate external media.

¹ For weather-related events, this process will generally begin approximately 3:30 a.m. and conclude with decision and communication, either way, by approximately 4:30 a.m., or as needed to monitor conditions throughout the day.
² If the CFO or Provost is off-campus or unavailable, the VP for Student Life and Dean of Students will serve as part of the primary decision-making team.
³ The VP for Marketing and Communication is consulted as early as possible in the decision-making process.

Cancellation Categories

Type 1: Cancellation/Delay/Closing Due to Weather

1. Certain employees’ presence on campus is mandatory regardless of cancellation or delay of college functions (referred to as weather–essential employees). Each department leader shall maintain and regularly update a list of such individuals to assure timely communication during these circumstances.
2. Individuals normally scheduled to work during a time of canceled activities are expected to be paid for regularly scheduled hours. If the College activities are not canceled and individuals choose to leave early due to inclement weather, the time off should be taken as unpaid leave, vacation, or PTO time with supervisor approval. 
3. In the interest of personal safety, with the exception of those weather-essential employees or those specifically called upon by a department leader, all other Faculty, Staff, and Administrators shall remain off campus until notified that buildings have reopened and classes and activities have resumed. 
4. The target time to finalize weather-related decisions will be between 4:00 a.m. and 5:00 a.m., with announcements prior to the start of official college business hours. 
   
   

Type 2: Cancellation/Closing Due to Catastrophic Event

1. When College facilities will be closed, classes cancelled or delayed during a work day due to catastrophic circumstances (e.g. chemical spill, major fire, building flooding, system outages, etc.), announcements will be made as outlined above under dissemination of information. 
2. Certain departments or individuals may be requested or required to remain on duty at the College during emergency closures due to a catastrophic event. These individuals may be on the ‘weather-essential’ employee list or may be other individuals deemed essential, due to the nature of the event. In the interest of personal safety, with the exception of those individuals whose presence is mandatory or specifically called upon by a department leader, all other Faculty, Staff, and Administrators shall remain off campus until notified that buildings have reopened and classes and activities have resumed.

Policy Implementation Assistance

Contact the Director of Environmental Health, Safety and Risk Management, CFO, Provost, or VP for Student Life and Dean of Students for questions and comments on this policy.

Policy Authority

The President’s Cabinet has responsibility for this policy and will obtain necessary approvals and changes to this policy.

Related Policies or References

Administrative and Support Staff Handbook; All College Policies.

Attachments: Flow Chart Links

• https://gustavus.edu/facultybook/concertFiles/media/Cancellation_Delay_Policy_Flow_Charts.pdf

Approved by the President's Cabinet: October 31, 2017; revised November 2019.

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Policy Regarding the Use of College Funds to Express Condolences at the Time of a Death

Upon learning of the death of a current or retired member of the College community, including a faculty member, staff member, Board member, or donor, an employee should, as soon as possible, alert the College and provide a link to the obituary, if available. Similar notification should be made when a spouse, child, or parent of members of the community pass away. In the case of a death of a current student or a student’s immediate family member, an employee should, as soon as possible, alert the Dean of Students Office.

The College will alert employees and offices who need to know of the death, including the Marketing and Communication Office for inclusion in appropriate publications. In addition, Campus Safety will be contacted by the Office of the President, and the Gustavus Flag will be flown at half-staff for a period of three days in memory of deceased faculty and staff (current or retired) and current students. An announcement regarding a death will not be sent unless the person affected, or that person’s family or representative, gives permission.

The Office of the President typically will send flowers or a fruit basket on behalf of the College when a current or retired faculty member, staff member, Board member, or significant donor passes. Floral arrangements shall be sent to the funeral home or location of the memorial service, or a fruit basket will be sent to the immediate family. In some circumstances when a death has occurred, the family may request a donation in lieu of flowers or a fruit basket. College policy prohibits using institutional funds for charitable donations. The Dean of Students Office will coordinate all arrangements when a current student or a current student’s immediate family passes. 

If departments or individuals would like to send a condolence for a faculty or staff member or a member of their family in addition to the condolence being sent by the College, they are encouraged to do so by using funds personally contributed by members and friends of the department.

Approved by the President's Cabinet: October 15, 2013. Revised April 16, 2024.

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1. Purposes

   1. To distinguish between (a) fundraising efforts in which Gustavus Adolphus College (hereafter “the College”) is an intended beneficiary and (b) fundraising activities in which the College is not a beneficiary but members of the College community may be participants,
   2. To set limits and offer assistance for members of the Gustavus Adolphus College community who wish to engage in fundraising activities outside those conducted in support of the College’s established priorities for philanthropic support,
   3. To clarify the College’s legal, fiduciary and moral responsibilities for acknowledging and stewarding the gifts it receives, and
   4. To provide education and guidance that will help prevent actions that could jeopardize Gustavus Adolphus College’s tax-exempt status.

2. Background

   1. The Office of Institutional Advancement

      The purpose of the Office of Institutional Advancement is to enable Gustavus Adolphus College to fulfill its mission by communicating its distinctiveness, facilitating life-long relationships and securing human and financial resources. Accordingly, the Office of Institutional Advancement must strive at all times to ensure that its policies and procedures are in compliance with local, state and federal regulations in regard to the solicitation and acceptance of gifts. Any deviation from the Internal Revenue Code could result in fines, public embarrassment and/or the loss of the College’s tax-exempt status.

      For these and many other reasons, all fundraising requests made in the name of Gustavus Adolphus College must be approved in advance by the Vice President for Institutional Advancement or the Vice President’s designate.

   2. Gustavus Adolphus College’s Tax-Exempt Status

      The ability of Gustavus Adolphus College to seek and receive philanthropic gifts and grants is dependent upon the continuing recognition of its tax-exempt status by the IRS. The College must protect this status by abiding by all relevant laws and regulations, including using its tax-exempt status solely for its own benefit and by not sharing it with other organizations. The Office of Institutional Advancement is charged by the College with responsibility for monitoring and protecting its tax-exempt status.

3. Policy

   This Policy shall apply to any and all members of the Gustavus Adolphus College community, as well as to any other individuals or organizations who may represent themselves to be members of the College community or who claim to be acting on behalf the College. This Policy does not apply to members of the College community when they are engaged in fundraising activities for other organizations and/or when they have explicitly stated that their fundraising activities are unrelated to the College.

   1. Definition of “College Fundraising” Activities

      A College fundraising activity is one that employs the name, image or reputation of Gustavus Adolphus College in an effort to secure financial contributions and also meets at least one of the following criteria:

      • The activity claims to be for the benefit of Gustavus Adolphus College,
      • The activity does in fact benefit the College,
      • Checks will be made payable to Gustavus Adolphus College,
      • Donors will expect gift receipt for tax purposes or will be promised a gift receipt.

   2. Advance Approval of Fundraising Activities

      All fundraising activities meeting the definition of “College fundraising activity” (see Section C1 above) must be approved in advance by the Vice President for Institutional Advancement or the Vice President’s designate.

   3. Gift Receipting

      The only College office authorized to issue an official gift receipt on behalf of Gustavus Adolphus College is the Office of Institutional Advancement. Such receipts will be issued only when a donor’s gift has been given for a purpose consistent with the College’s mission and when the donor has not retained any control over the gift’s use or demanded goods or services in consideration for their gift.

   4. Process for Seeking Approval

      Any potential fundraising activities on behalf of a College program or initiative must first be formally communicated to the appropriate divisional director or vice president before a request for assistance is directed to the Office of Institutional Advancement. Examples of proposed fundraising activities might include, but are not limited to: departmental grants, underwriting of conference participation, sponsorship of an on-campus symposium, student or faculty travel, equipment, or departmental awards and banquets.

      If a divisional director or vice president, or their designate, endorses a proposed fundraising project, it may then proceed to the Office of Institutional Advancement.

   5. Appeal Process

      Any fundraising activity or solicitation that is not approved by the Office of Institutional Advancement may be appealed, in writing, to the Vice President for Institutional Advancement.

   6. Counsel and Training

      The Institutional Advancement staff will offer assistance to members of the College community interested in advancing the College through fundraising techniques; however, no formal planning for specific fundraising projects will be conducted without the approval of the appropriate vice president(s). Once approval for a fundraising activity is received, the Institutional Advancement team is available to consult with faculty, staff and student leaders on strategies and tactics for their College-endorsed initiatives. Responsibilities for follow through will also be assigned and an appropriate Institutional Advancement contact person may be identified.

   7. Lists of Donors and Potential Donors

      The Office of Institutional Advancement will not share lists of donors or other constituents with individuals and organizations. The lists will be processed and sent directly to the mailroom for completion. The College will honor the wishes of donors who ask that their giving to the College be anonymous.

   8. Processing of Gifts

      Contributions received in response to an approved fundraising initiative must be submitted to the Office of Institutional Advancement within 48 hours. Cash contributions must be accompanied by the original envelope in which they are received. The donor’s name and address must be clearly written on the envelope.

4. The College and Non-College Fundraising Initiatives

   The College is aware that students and employees often engage in fundraising activities for which the College is not the intended beneficiary. These activities may range from campus-based efforts to raise funds for groups such as the Susan G. Komen Breast Cancer Foundation or Habitat for Humanity to employee or student participation in their local churches or clubs.

   As stated above, when the activities are intended to benefit Gustavus Adolphus College, they must be approved in advance by the Vice President for Institutional Advancement or the Vice President’s designate. When an activity is not intended to benefit Gustavus Adolphus College, administrative approval is not required, but the utmost care must be taken to make that distinction clear and to not lead outsiders to believe the activity is a College-supported effort.

   1. Actions that suggest College participation and support:

      • Asking that checks be made payable to Gustavus Adolphus College
      • Employing the College’s name or logo in promotions or solicitations
      • Using College stationery
      • A volunteer stating, “As a Gustavus Adolphus College student/faculty/staff member, I am asking you….”

   2. Actions that avoid confusion:

      • Stating that “This is an event that will benefit [Name of Charity]”
      • Asking that checks “Be made payable to [Name of Charity]”
      • Stating that “This event is not affiliated with Gustavus Adolphus College”

   3. When is College Approval Needed?

      Here is a simple test to determine if College approval is needed: If it appears that the contemplated fundraising activity cannot be conducted without making contribution checks payable to Gustavus Adolphus College, then the activity is one that will require prior approval by the Vice President for Institutional Advancement or the Vice President’s designate and organizers should follow the process outlined in Section C.4. above.

   4. Prohibited Activities

      Even when a fundraising activity is not one that benefits the College directly or is sanctioned by the College, members of the College community are prohibited from engaging in the following tactics and activities:

      • Using home addresses from the College telephone directory to compile calling or mailing lists*
      • Using the Gustavus Adolphus College Alumni Directory to compile calling or mailing lists*
      • Using one’s status as a Gustavus Adolphus College employee or student to secure a gift commitment
      • Using “blast e-mails” on the campus intranet system to solicit gifts
      • Conducting lotteries or similar games of chance, which the State of Minnesota defines as gambling.

      * Note: The publishers of these directories also consider these activities to be violations of their copyrights.

Approved by the President’s Cabinet: November 10, 2010.

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Purpose
Gustavus Adolphus College is committed to the safety of all individuals in its community. The Policy for the Protection of Minors (“the Policy”) establishes guidelines for all faculty, staff, students and volunteers in the College community who may work or interact with individuals under 18 years of age, with the goal of promoting the safety and well-being of minors. The Policy is applicable to College-affiliated programs. Non-College affiliated program requirements will be outlined in a facility use agreement (contract) with each respective program. 

Definitions
A Child is a person under the age of thirteen (13) years. A Minor is a person under the age of eighteen (18) years. 

Policy Statement 
It is the policy of Gustavus Adolphus College that the behavior of all faculty, staff, students and volunteers of our community is expected to align, at all times, with the College’s mission and appropriate documents that guide our community life. Any Gustavus Adolphus College event with minors involved must be pre-approved by the appropriate Vice President. Any Gustavus faculty, staff, student or volunteer participating in events with minors must complete an online Sexual Abuse Awareness Training. In addition, faculty, staff, student or volunteers with potential to have one-on-one contact with minors must successfully pass a background check prior to the event occurring. This Policy does not apply when minors attend an event open to the public, with their parents or guardian, and who are not left in the care of Gustavus Adolphus College employees or students.

This policy is not intended to apply to current, full-time Gustavus students who are not yet 18 years old. With regard to this policy, College faculty and staff on campus who only interact with Gustavus Adolphus College undergraduate students under the age of 18 in classes or other traditional academic settings are not required to undergo the training or background check. However, faculty and staff affiliated with the College who knows or suspects that an undergraduate student under the age of 18 has been abused or neglected MUST make reports as required by this Policy.

Procedures
Faculty, staff, and volunteers affiliated with the College who host an event with minors in attendance must receive approval before hosting minors on campus or participating in a Gustavus Adolphus College event off campus with minors. The approval can be requested by submitting a Request to Host Minors Form. * This does not apply to students who are hosting family members. Whenever possible, the request should be submitted at least two weeks prior to the event. 
If the event is approved, the following steps must be completed:

1. All employees, students or volunteers participating in the event must complete the online Sexual Abuse Awareness Training prior to the event occurring.

2. The following categories of adults involved in a College-affiliated program or activity are required to undergo a background check prior to their participation in College activities or programs involving minors:

1. Directors, supervisors and faculty members for programs involving minors, including those who are responsible for supervising those who interact with minors;
2. Those who stay overnight with minors as part of their job responsibilities in a program or activity involving minors; and
3. Those who regularly spend time with minors as part of their job responsibilities or role in a program involving minors.
   The Vice President of Student Life and/or the Title IX Coordinator can request that a background check be performed on any faculty, staff, student or volunteer involved with a College affiliated program that does not fit in the aforementioned categories.

The Office of Human Resources will oversee the processing of background checks for all College-affiliated programs and activities involving minors. Background checks should be completed every five years or re-checked if an employee separated employment for more than one year, unless they were working consecutive short-term or temporary assignments, in which case the five-year policy applies. The cost of the background check will be the responsibility of the department hosting the event.

3. The program director/instructor is responsible for collecting the Parent Permission and Registration Form and Child Behavior Agreement for every minor left in Gustavus’s care for their program. If minors are participating as part of a group, such as a school, the Group Guest Policies and Behavioral Expectation Agreement should be completed by the group instead of filling out a form for each child. If minors are attending an event and will be under the care of their parent or guardian, neither form needs to be completed. (The completed forms should be turned in to the Dean of Students Office). 

4. An appropriate number of adult supervisors will be present at each event based upon the activity. Whenever possible, allow for two individuals to be present for circumstances such as taking a minor to the restroom or taking a minor aside if they get hurt. 

Residential Camps, Conferences and Events 

● Residential camp, conference and event staff must successfully complete an approved background check. 
● Residential camp, conference and event staff must fully complete online Sexual Abuse Awareness training. 
● Event staff with access to room keys must be in compliance with appropriate laws.
● Residences will be staffed at a ratio recommended by Gustavus Adolphus College. (staff ratio 20:1)
● Posted signs in each residence hall will give clear direction on how to contact staff or Campus Safety if a guest feels unsafe.
● Residence hall bathrooms will be assigned by age when appropriate, as well as gender. 
● Campers and guests will be directed and expected to lock rooms at night. 
● Residential areas will be off limits to anyone who is not a camper/guest or appropriate staff.
● Program leaders must include a safety session during their event orientation meeting.

Prospective Student Admission Visits 
● All overnight admission guests must adhere to and comply with the College’s behavioral expectations and rules.
● All overnight admission guests must complete an emergency contact form.
● Guests will be given clear direction on how to contact staff or Campus Safety if they feel unsafe.
● The Dean of Students Office must approve that a student can serve as a residential host, following a check of College records.
● All residential hosts must complete the online Sexual Abuse Awareness training prior to serving as a residential host.

 One-to-one Instruction or Tutoring of Minors on Campus
● All College employees or students who are giving lessons, instruction or tutoring to minors on campus must submit the Request to Host Minors Form for approval prior to starting lessons. If the lessons are approved, the Instructor must complete and satisfactorily pass an approved background check and complete the online Sexual Abuse Awareness Training. 
● Rooms or studios used for instruction or tutoring must have a window that allows unobstructed views into the space. If no window is available, the door must remain open throughout the session.
● Tutoring should be conducted in a public area such as open library areas and should not be conducted in a residence hall or off-campus home. 
● Parents or guardians will not be restricted from attending sessions with their minor children.

Oversight 
The Vice President for Student Life is the primary point of contact for this Policy. The following individuals are responsible for oversight of minors on campus in their applicable areas: 
● Associate Vice President of Auxiliary Services: Events involving minors that run through the Summer Programs Office 
● Vice President for Enrollment: Admission events and prospective student visits 
● Provost of the College: Any academic department event involving minors
● Director of Campus Activities: Any student organization or event involving minors
● Director of Community Engagement: Related programs involving minors
● Church Relations: Related programs involving minors
● Director of Athletics: Any event related to athletics involving minors
● Vice President for Student Life: All other Gustavus Adolphus College events involving minors that are not listed above 

This oversight includes:
● Approving or denying Requests to Host Minors 
● Ensuring that online training is complete for all required individuals
● Ensuring any necessary background checks are completed and approved through the Office of Human Resources.
● Retaining all documents. 

Reporting of Sexual Abuse, Neglect or Misconduct
Faculty, staff, students and volunteers affiliated with the College who are participating in a program or activity that involves minors, who know, suspect, or receive information indicating that a minor has been abused or neglected, MUST notify the Nicollet County Department of Human Services by calling 507-386-4528 or by calling the Nicollet County Sheriff at 507-931-1570. 
Additionally, ANY reporter of known or suspected abuse or neglect of a minor must promptly inform the College’s Title IX Coordinator by phone at 507-933-6360 or email at jwatter2@gustavus.edu. A written report must also be submitted to Nicollet County within 72 hours of the oral report. The Title IX Coordinator will assist the reporter in this process. For more information on reporting requirements or definitions of physical abuse, sexual abuse or neglect, please see the Minnesota Department of Human Services website: https://mn.gov/dhs/people-we-serve/children-and-families/services/child-protection/ 
Upon receipt of a report of alleged abuse or neglect of a minor in a College-affiliated program or activity, the College’s Title IX Coordinator (or designee), shall:
● Take immediate steps to prevent further harm to the alleged victim or other minors.
● Facilitate the College’s cooperation with any investigation conducted by the Nicollet County Sheriff, Nicollet County Department of Human Services, or other governmental agency.
● Investigate the report and resolve the matter in a way that safeguards the minor, protects the interests of victims and reporters and affords fundamental fairness to the accused.
If a report identifies/alleges that someone involved in an activity on campus who is not a member of the College faculty, staff, volunteer or student body has abused or neglected a minor, the person receiving the report shall report to the Title IX Coordinator, even if they believe the Coordinator has already been notified. The College’s Title IX Coordinator will coordinate with the reporting party the appropriate reporting structure as outlined above to ensure that all reporting obligations are accomplished. 
Upon being notified of a sexual misconduct or abuse incident involving a minor, the College’s Title IX Coordinator shall notify the Gustavus Adolphus College Risk Manager who will in turn notify the liability insurance company of the incident.

Enforcement
Any report of abuse of a minor by any faculty, staff, volunteer or student of the Gustavus Adolphus College community will be investigated by the appropriate College campus authority. Sanctions for violations of this Policy will depend on the circumstances and the nature of the violation, but may include the full range of available College sanctions applicable to the individual including suspension, dismissal, termination, and, where appropriate, exclusion from campus. The College may also take necessary interim actions before determining whether a violation has occurred.

Approved by the Gustavus Adolphus College Board of Trustees: May 15, 2020.

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Purpose of Policy

The purpose of the WellsOne Commercial Card Program is to simplify the purchasing and payment process for Gustavus transactions. This document will provide you with specifics of the program. Please read this document carefully as you will be held accountable for its contents.

Owner

CFO and VP for Finance and Treasurer.

Card Issuance and Activation

To obtain a card, you must complete the following steps:

• Department Chair, Budget Officer, and/or Approver must initiate request for issuance of new P-card.
• Attend a brief, mandatory training session where card policies and procedures will be reviewed.
• Sign the Cardholder Agreement.
• Obtain your new card and login information to access the Wells Fargo online system.
• Sign the back of the card and keep the cardholder information in a secure location.
• Activate your card by calling the toll-free number on your card. For verification purposes, you will be asked to provide your unique identifier (last four digits of your social security number).

Using your Purchase Card

• Once you activate your card, you can begin making purchases immediately.
• A monthly credit limit has been placed on your card. If you feel this amount is inadequate for your purchase needs, contact a program administrator in the Finance Office. Once approved, adjustments in credit limits will be effective immediately.
• All accounts payable policies and procedures established by the College still apply and include:
  • All purchases are the property of the College and must be delivered to the College’s address.
  • For entertainment expenses, you must document who, what, why, when and where to comply with IRS regulations.
  • For year-end purchases, your item must be received on campus by May 31.
  • Before traveling on College-related business, review the travel policy to ensure you are familiar with the College’s policies and procedures.
• Certain merchant category codes (MCC) have been blocked which may result in a denied transaction.
• Cash withdrawals are not allowed, except in rare circumstances.
• Personal expenses are not allowed.
• Misuse of your card may result in disciplinary action, including revocation of card by Finance Office and/or in extreme cases, termination.

Misuse of Purchase Card and Related Consequences

When the Cardholder Agreement is signed, the cardholder states that they agree to comply with the policy as laid out by Gustavus in this manual. Failure to do so is referred to as an “infraction”. Some examples of infractions include (but are not limited to) the following items:

• Personal Purchases not reimbursed to Gustavus within eight days of the end of the month of purchase.
• Failure to meet reconciliation deadlines as specified in the ‘Reconcilement of Monthly Statement’ section in this document.
• Failure to resolve being charged State of Minnesota sales tax.
• The purchase of unauthorized items.
• Negligence in preventing the loss or theft of a card or in the reporting of a loss or theft.

The Finance Office reserves the right to cancel or suspend a purchase card at any time. However, the standard escalation process of the consequences for infractions is as follows:

• Email to cardholder
• Second email to cardholder with copy to supervisor
• 60-day card Suspension
• One year card suspension (must reapply after one year)

Sales Tax Exemption

Merchants are usually required by tax authorities to include sales and use tax at the time you purchase goods. The amount is dependent on a variety of factors, including the state, county and city where you are purchasing goods. It is the cardholder’s responsibility to notify the vendor that Gustavus is tax exempt. For your convenience, the sales tax-exempt number is printed on the purchase card. The sales tax-exempt number may not be used for any other purpose than for purchases for the College. Cardholders may not share this number with other individuals. Cardholders who neglect to provide the sales and use tax exempt number to merchants may find themselves personally obligated to repay said charges to the College. Generally, sales tax exemptions are on items purchased in or delivered to Minnesota. In the event the merchant refuses to remove the sales tax, the cardholder should ask to speak to a manager and direct them to https://gustavus.edu/finance/ where they can access a copy of our MN ST-3 Certificate of Exemption.

Reconcilement of Monthly Statement

The billing cycle ends on the last business day of each month, but it is strongly recommended that you review and code your expenses throughout the month so errors can be detected immediately. If someone else codes and reconciles your expenses, we ask that you bring your receipts to them as your expenses are incurred. On the 8th day of each month (or the first business day thereafter), all coding needs to be complete. On the 12th day of each month (or the first business day thereafter), the previous month’s period will be closed and there will be no access to make changes to or approve expenses. If there are outstanding expenses that have not been approved by that day, the Finance Office will contact the proper approver and notify them that they need to come to the Finance Office to sign the hard copy of the statement. On the 15th day of each month (or the first business day thereafter), the statements and supporting documentation are due in the Finance Office.

Listed below are the procedures for completing the review and approval of your statement:

• Review postings to your card during the last statement period. It is strongly encouraged that you review this on an ongoing basis rather than waiting until the end of the month.
• Review fund number, department code, and object code for accuracy.
• Receipts are required for all transactions regardless of dollar amount. Attach all original detailed receipts to your statement and check box that receipt is attached. If you are using the internet to make your purchase, make sure you print and attach the confirmation of your purchase.
• If a receipt is missing and you have done your due diligence in trying to obtain one, you will need to fill out a missing receipt declaration. You will also need to add a note to the transaction description stating that you cannot obtain a receipt and the reason why. Note description of items purchased. If your purchase is for entertainment expenses, you must document who, what, why, when, and where as required by IRS regulations. You will not be allowed to forward your expenses to your approver until a description is noted.
• Submit your expenses to your supervisor for approval.
• Print a copy of your statement and attach your original receipts. Send to the finance office for review by the 15th day of the month. All statements and receipts will be retained for seven years.

Payment of Charges

Gustavus makes a single payment to Wells Fargo each month for all purchases. Cardholders do not have to submit a request for payment.

Cards issued under the WellsOne Commercial Card Program are individually issued to cardholders; however, use of the card or payment by the College does not affect the cardholder’s personal credit rating.

Cardholder Maintenance

Contact the Finance Office to:

• Cancel a card (must call Wells Fargo to report lost or stolen).
• Change of the name on a card (i.e., change in status).
• Change of employee job responsibilities.
• Change credit limit on a card.
• Request a replacement card (i.e., numbers wearing off).

Transaction Dispute Resolution

Transactions may be placed in dispute when charges appear on the statement that the cardholder did not make, the amount of the charge is incorrect or there is a quality or service issue with the purchase.

The cardholder is responsible for contacting the merchant involved to resolve the error. If the merchant agrees that an error has been made, the merchant will credit the account. Cardholders are advised to keep detailed notes including dates, times, name of person contacted, etc.

Cardholders are required to initiate the dispute process within 60 days of the transaction date in order to protect your rights. Failure to notify the financial carrier of a disputed charge on an account within 60 days will prevent the College from reversing the charges on the account. Cardholders may be held personally responsible for failure to comply with this component. Wells Fargo will resolve disputed transactions within 90 days.

Lost or Stolen Cards

Cardholders are responsible for the safety and security of the purchase card issued to them. For lost or stolen cards:

• Notify Wells Fargo immediately at 800-932-0036
• Notify a program administrator: Kelly Mans 507-933-7508 or Chris Germscheid 507-933-7201
• Notify Campus Safety and the appropriate local authorities, if applicable

Policy Implementation Assistance

Contact the CFO, Controller, Senior Accountant, or Accounts Payable Specialist for questions and comments on this policy.

Policy Authority

The Executive Leadership Team has responsibility for this policy and will obtain necessary approvals and changes to this policy.

Related Policies or References

Travel and Entertainment Policy; All College Policies.

Approved by the President’s Cabinet: January 1, 2005. Updated and approved by the Executive Leadership Team September 2024.

Purpose of Policy

Tax exempt debt used for the benefit of Gustavus Adolphus College (“the College”) by the Minnesota Higher Education Facilities Authority (“MNHEFA”) is a lower cost alternative to taxable debt and a valuable tool for financing capital projects. The interest on the bonds that is paid to bondholders is excluded from Federal and Minnesota income tax if applicable Federal tax laws are satisfied. The requirements fall under two categories – prior to issuance and after issuance. A signed bond counsel opinion at closing is assurance that the requirements that must be satisfied on or prior to issuance have been addressed. In order for the bonds to remain tax exempt through maturity, certain other requirements must be met.

Who Needs to Know This Policy

College staff involved in some aspect of any bond issue who direct or influence the following processes:

• Pre-issuance processes and decision-making including identification of eligible projects and due diligence on tax aspects of the project(s)
• The use of bond proceeds and timing of expenditures
• Investing of bond proceeds and arbitrage yield restriction and rebate processes
• Private use of property financed by tax-exempt bonds, including leases, and management and services agreements
• The creation and retention of documentation relating to use of proceeds, investment restrictions and arbitrage rebate calculation, return filings, and private usage
• Recording and reporting of financial transactions related to tax-exempt bonds and bond financed projects

Definitions

Qualified 501 (c)(3) bonds – Tax-exempt bonds, the proceeds of which are used by a 501 (c)(3) charitable organization in furtherance of its exempt purpose. The bonds are issued by a state or local government agency such as the Minnesota Higher Education Facilities Authority and are supported by a repayment obligation from the charitable organization to the governmental agency.

Private business use – Examples of private business use include: 1). Unrelated trade or business use and 2). Private use by parties other than the charitable organization of the tax-exempt debt-financed property. Generally, no more than 5% of the proceeds of tax exempt bonds may be used for private business use of the tax-exempt financed property. For purposes of the 5% limit on private business use, bond issuance costs financed with bond proceeds (approximately 2%) are included as private business use, so typically, private business use is limited to 3%.

Arbitrage – Investment earnings on bond proceeds in excess of bond interest paid to bondholders during the construction period, adjusted for certain expenses.

Applicable Federal law – Includes the Internal Revenue Code and regulations promulgated thereunder, including IRC sections 145-150 and related regulations. Note: IRS Publication 4077, Tax-Exempt Bonds for 501 (c)(3) Charitable Organizations Compliance Guide provides guidance and explanation for most areas of tax-exempt financing relevant to the College.

Tax certificate – The loan agreement and certificate as to tax matters signed by the College at the closing of the bond issue in which the College makes certain representations, warranties and covenants relating to its 501 (c)(3) status, the tax eligibility of the project(s) and the College’s operations.

Treasurer’s Office – The employee of the College holding the title of Vice President for Finance and Treasurer.

Policy

It is the College’s policy to comply with applicable Federal tax laws to ensure that bonds issued for its benefit maintain their tax exempt status. The College will incorporate the guidelines of the office of Tax-Exempt Bonds of the Internal Revenue Service, Tax Exempt and Governmental Entities division, in Publication 4077 and the Article “TEB Post Issuance Compliance: Some Basic Concepts” to establish post issuance compliance procedures. The procedures will be reviewed annually and updated as needed to reflect changes in requirements or the IRS guidelines for post issuance compliance procedures.

Use of bond proceeds and project eligibility - The College will comply with all applicable Federal, State and contractual restrictions regarding the use and investment of bond proceeds. Bond proceeds shall be disbursed for:

• Project costs
• Capitalized interest
• Bond issuance costs, including arbitrage rebates

To be an eligible project, the property being funded must be owned or, under certain circumstances, leased by the College and the intended use must be consistent with the College’s 501 (c)(3) exempt purposes. In addition, the project’s address must be listed in the TEFRA notice. The Treasurer’s Office will apply additional technical criteria to determine eligibility of the project(s) (e.g. useful life of project(s)).

Timing of the use of bond proceeds – At the time that the bonds are issued, it must be intended and expected that the project(s) will be completed within three years of issuance.

Private business use of tax-exempt financed property – Five percent or less of bond issue proceeds may be used for private business purposes, and such use may only occur if an accordance with tax certificate provisions and in compliance with applicable Federal law. Costs of issuance are counted against the 5% limit. The Treasurer’s Office annually analyzes the status of the tax-exempt financing with regard to the private use limitations.

Change of use – Change of a project’s use or contemplated change of use must be reported to the Treasurer’s Office prior to the implementation of the proposed change in use to ensure compliance with applicable regulations.

Arbitrage – The Internal Revenue Code (Section 148 and the Regulations thereunder) provides that interest on bonds is not exempt from tax if the bonds are arbitrage bonds. To the extent required by applicable laws, regulations and bond covenants, the College will comply with all arbitrage rebate requirements. The Treasurer’s Office will annually determine any accrued rebate liability, record the liability in the financial statements, and make provisions for reserving funds for rebate purposes.

Sale of property involving bond proceeds – Prior to the time that property involving bond proceeds is sold, the Treasurer’s Office will contact the Executive Director of MNHEFA and bond counsel of the College to discuss potential ramifications.

Filing of returns – The Treasurer’s Office works with Springsted Incorporated, the financial advisor for the MNHEFA, to prepare and file returns with the IRS relating to arbitrage.

Annual monitoring – The Treasurer’s Office will monitor for compliance of College debt with bond covenants and Minnesota and Federal laws and regulations. A debt covenant spreadsheet is updated on an annual basis by the Treasurer’s Office.

Education – The Treasurer’s Office will seek education and training on updates to Federal tax law regarding tax-exempt bonds from MNHEFA.

Record retention – The records relating to tax-exempt bonds (use and investment of proceeds) shall be maintained for the entire term of the bonds issue plus three years, or in the case of an issue refunded by one or more subsequent issues, for the combined term of the issues plus three years.

Noncompliance-If discovery that any applicable tax restrictions regarding use of bond proceeds and bond-financed assets may be violated, the College will consult promptly with bond counsel and the Executive Director of MNHEFA to determine a course of action to remediate all non-qualified bonds, if such counsel advises that a remedial action is necessary.

Approved by the President’s Cabinet: December 17, 2013.

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I. Scope

This policy applies to:

• Gustavus Adolphus employees and students operating Unpersoned aircraft systems (UAS) in any location as part of their College employment or as part of College activities;
• The operation by any person of Unpersoned aircraft system or model aircraft on or above Gustavus Adolphus property;
• The purchase of Unpersoned aircraft systems with funding through Gustavus Adolphus, including College accounts, grants, or foundation accounts and;
• The hiring for or contracting for any Unpersoned aircraft services by a Gustavus Adolphus unit.

II. Purpose of Policy

Gustavus Adolphus must comply with Federal Aviation Administration (FAA) requirements, Gustavus Adolphus College policy, and any other locally applicable laws or regulations regarding Unpersoned aircraft systems. Inherent risks in the operation of such equipment require additional insurance provisions and policy considerations..

III. Policy Statement

The operation of Unpersoned aircraft systems including drones and model aircraft is regulated by the FAA and relevant state law. Therefore, all individuals who operate UAV or UAS systems on the Gustavus Adolphus College campus are personally responsible for complying with FAA regulations, state and federal laws, and College policies regarding use of Unpersoned aircraft systems. Gustavus Adolphus has established procedures to ensure compliance with those legal obligations and to reduce risks to safety, security and privacy considerations.

IV. Procedures

A. The operation of a drone, UAV or UAS over and/or inside Gustavus Adolphus College property is prohibited without the written approval of the Gustavus Director of Campus Safety (or his/her designee).

B. Individuals wishing to operate an UAS as part of their College employment or as part of a College program must obtain a 333 exemption or Certification of Waiver or Authorization (COA) issued by the FAA and submit it with an application for UAS use*. Application forms may be obtained at the Campus Safety Office, 035 Norelius Hall.

C. Any College employee, student, or unit purchasing a UAS (or parts to assemble a UAS), or UAS services with College funds or funds being disbursed through a College account, or grant funds, must contact the Director of Campus Safety in order to assess the College’s ability to obtain a COA, other necessary FAA exemptions, or meet local compliance requirements.

D. College owned UAV’s and UAS’s need to be registered with the campus safety office and reported to the College’s insurance carrier. Application forms may be obtained at the Campus Safety Office, 035 Norelius Hall.

E. Any third party or hobbyist wishing to use a UAS or model aircraft over and/or inside Gustavus College property must first receive approval through the Director of Campus Safety. In order to obtain approval, any operator that is not a College employee or student conducting work on behalf of a College program, must file an application and submit a $1,000,000.00 general liability insurance certificate to the Director of Campus Safety at least 72 hours prior to the planned operation.** Application forms may be obtained at the Campus Safety Office, 035 Norelius Hall.

F. Third parties or hobbyists planning the use of UAS must also provide proof of FAA approval. In addition, operation of UAS by a third party or hobbyist over College property must be under a contract which holds the College harmless from any resulting claims or harm to individuals and damage to College property and provides insurance as required by the Director of Campus Safety. In operating a UAS for purposes of recording or transmitting visual images, operators must take all reasonable measures to avoid violations of areas normally considered private. Minnesota law provides that a person who surreptitiously installs or uses any device for observing, photographing, recording, amplifying, or broadcasting sounds or events through the window or other aperture of a sleeping room in a hotel, as defined in section 327.70, subdivision 3, a tanning booth, or other place where a reasonable person would have an expectation of privacy and has exposed or is likely to expose their intimate parts, as defined in section 609.341, subdivision 5, or the clothing covering the immediate area of the intimate parts; and commits a gross misdemeanor.

G. Once approved for the use of a UAS device by the Director of Campus Safety, Campus Safety should ensure proper notification of local law enforcement and aviation agencies.

H. All data collected from a UAS through an agreement between Gustavus Adolphus College and a third party, is the intellectual property of Gustavus Adolphus.

I. Any operator of a UAS (i.e. person actually flying the UAS, whether College employee, student, hobbyist or third party) must be at least 17 years old, passed an aeronautical knowledge test (to be taken every 24 months to maintain certification) and has an FAA UAS operator certificate. In addition,

1. Flights are limited to daylight hours and in good weather.
2. Flights are limited to 500 feet altitude and no faster than 100 mph.
3. UAS must weigh less than 55 pounds.
4. Operator is responsible for ensuring an aircraft is safe before flying (i.e. perform a preflight inspection that includes checking the communications link between the control station and the UAS, assess weather conditions, location of people, etc.).
5. Operator must maintain visual line of sight of the UAS with unaided vision (except for eye glasses).
6. Operator must discontinue the flight when continuing would pose a hazard to other aircraft, people or property.
7. UAS cannot be flown over people, except for those directly involved in the flight.
8. Operating the UAS in a careless or reckless manner is prohibited.
9. Dropping any objects from the UAS is prohibited.
10. Operator must respect the privacy of others- avoid flying over private property or taking photos or videos without permission.

* The Gustavus Director of Campus Safety is the FAA account holder for COAs for the College; the Director reviews and processes all applications on a case-by-case basis.
** An application may be denied if an individual fails to provide proof of insurance, FAA registration of their device (if required) or proof of a remote pilot certificate.

V. Appropriate and Prohibited Uses

A. UAS shall not be used to monitor or record areas where there is a reasonable expectation of privacy in accordance with accepted social norms. These areas include but are not limited to restrooms, locker rooms, individual residential rooms, changing or dressing rooms, and health treatment rooms.

B. UAS shall not be used to monitor or record residential hallways or residential lounges.

C. UAS shall not be used to monitor or record sensitive institutional or personal information that may be found, for example, on an individual’s workspace, on computer or other electronic displays.

Definitions

Gustavus Adolphus Property – Buildings, grounds, and land that are owned by Gustavus Adolphus College or controlled by Gustavus Adolphus College via leases or other formal contractual arrangements to house ongoing Gustavus operations.

COA – Certificate of Authorization or Waiver. According to the FAA, the COA is an authorization issued by the Air Traffic Organization to a public operator for a specific UA activity. After a complete application is submitted, FAA conducts a comprehensive operational and technical review. If necessary, provisions or limitations may be imposed as part of the approval to ensure the UAS can operate safely with other airspace users. In most cases, FAA will provide a formal response within 60 days from the time a completed application is submitted.

333 Exemption – FAA exemption based on Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) which grants the Secretary of Transportation the authority to determine whether an airworthiness certificate is required for a UAS to operate safely in the National Airspace System.

Unpersoned Aircraft Systems (UAS) – UAS are also known as or may be characterized as Drones. According to the FAA, a UAS is the Unpersoned aircraft and all of the associated support equipment, control station, data links, telemetry, communications and navigation equipment, etc., necessary to operate the Unpersoned aircraft. UAS may have a variety of names including quadcopter, quadrotor, etc. FAA regulation applies to UAS regardless of size or weight. Model aircraft are not considered by the FAA as UAS and have different regulations.

Model Aircraft – Model aircraft are considered differently by the FAA than other UAS and have different regulations. Model aircraft are not for business purposes, only for hobby and recreation. (Use of UAS related to Gustavus Adolphus College does not qualify as model aircraft regulations.) Model aircraft must be kept within visual sightline of the operator, and should weigh under 55 pounds unless certified by an aeromodeling community-based organization. Model aircraft must be flown a sufficient distance from populated areas.

VI. Sanctions

Any violations of College policies by an individual will be dealt with in accordance with applicable College policies and procedures, which may include disciplinary actions up to and including termination from the College. Students who violate this policy may be subject to discipline through the Gustavus Adolphus College disciplinary conduct system. Disciplinary action for employees who are in violation this policy will be determined by their supervisor, in consultation with the Director of Campus Safety and any other affected parties.

Legal prohibitions regarding physical presence on campus/trespassing and other legal action may also be pursued against third parties that operate UAS in violation of this policy.

Fines or damages incurred by individuals or units that do not comply with this policy will not be paid by Gustavus Adolphus College and will be the responsibility of those persons involved.

Approved by the President’s Cabinet: October 11, 2016.

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A Gustavus Adolphus College student, parent, employee or guest may feel the need to lodge a formal complaint with the College, which they wish to have addressed.

To be considered a formal complaint, the complaint must meet the following criteria:

1. Be written; (complaints received via email would qualify as written)
2. Be identified as a formal complaint;
3. Be received by the College President, Provost, or one of the Vice Presidents; and
4. Include a complainant’s name and signature.

All formal complaints will be reviewed by the senior administrator to whom it was sent for credibility. Senior administrators may respond to the complaint or forward it on to appropriate parties within the College for response. All formal complaints will be responded to by written answer to the complaining party within one week. If the response to the complaint takes longer to answer than one week, a written timeline will be sent to the complaining party outlining when they could expect a response. All answers shall be deemed final and shall have no appeal process.

When applicable, responses to formal complaints will inform the complaining party of how the institution will integrate the complainant’s concerns into plans for college process and/or improvement.

All formal complaints and documentation of responses will be maintained within the Office of the Provost for a period of ten years.

This Institutional Complaint Policy is not a substitute for the more specific grievance and appeal processes maintained by college offices (such as the Office of the Registrar, Academic Affairs, Human Resources, etc.), Faculty Personnel Files policy 2.1.3 in the Faculty Handbook or the Student Conduct Policies and Procedures.

Unresolved complaints may be brought to the Minnesota Office of Higher Education, 1450 Energy Park Drive, Suite 350, St. Paul, MN 55108 / https://www.ohe.state.mn.us/ / 651-642-0533. If you reside in a state other than Minnesota, your unresolved complaint can be directed to your state’s Office of Higher Education using this list of state contacts: https://www2.ed.gov/about/contacts/state/

Approved by the President's Cabinet: January 8, 2013. Revised January 13, 2023.

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1. Employee-Student

Due to the inherent risk of favoritism, conflicts of interest, sexual harassment, and coercion, Gustavus Adolphus College employees are prohibited from engaging in any dating, romantic, or sexual relationship with a currently enrolled Gustavus student. This policy applies even to relationships considered to be consensual. This policy does not apply to previously existing employee/student marriages or domestic partnerships, as defined by College policy, or to a student worker in a consensual relationship with another student over whom they exercise no supervisory or evaluative authority.

An employee who violates this all-college policy will be subject to discipline up to and including dismissal. Furthermore, should any legal claims arise out of a relationship violation of this policy, Gustavus Adolphus will not indemnify the offending employee and will seek to recover its legal fees and expenses incurred to defend such claims.

As with other violations of college policies, anyone who becomes aware of such a relationship is expected to use one of the following reporting mechanisms to share this information:

• Contact the Director of Human Resources (507-933-6535)
• Contact the Campus Conduct hotline (866-943-5787)
• Make a report through Campus Safety (507-933-8888)

2. Employee-Employee

To the extent possible, dating, sexual, or romantic relationships between employees working within the same department or unit should be avoided even when the relationship is considered to be consensual.

Consensual dating, romantic, or sexual relationships between Gustavus Adolphus College employees in a supervisory relationship are prohibited. Where an amorous relationship previously exists or develops during the course of employment, the person in the position of greater authority or power will bear the primary burden of accountability. The superior must ensure that he or she does not exercise any supervisory or evaluative function over the other person in the relationship. In such instances, the superior must promptly notify his or her supervisor or dean in writing of the relationship and the dean or supervisor must implement alternative supervisory or evaluative arrangements.

An employee who fails to follow this policy will be subject to discipline up to and including dismissal. Furthermore, should any legal claims arise out of a relationship violation of this policy, Gustavus Adolphus College will not indemnify an employee accused of harassment or other unlawful conduct and will seek to recover its legal fees and expenses incurred to defend against such claims.

Approved by the Gustavus Adolphus College Board of Trustees: April 22, 2016. Updated and approved by the Executive Leadership Team October 29, 2024.

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Purpose and Applicability

The purpose of this policy is to set forth the policy of Gustavus Adolphus College (“Gustavus” or “the College”) on disclosure of misconduct and to protect individuals from retaliation in the form of an adverse employment action for disclosing what they believe evidences certain unlawful or unethical practices. This policy is applicable to all employees of Gustavus and to applicants for jobs at the Gustavus.

Statement of Policy

It is the policy of Gustavus that employees and applicants shall be free without fear of retaliation to report conduct within the College that they reasonably believe may constitute misconduct including, but not limited, to the following: wire fraud, mail fraud, bank fraud, securities fraud or questionable accounting and internal controls, auditing matters, harassment, discrimination, hostile workplace, safety and security issues, illegal or unethical business practices, wrongful termination, hate messages, faculty manual violations, administrative and staff manual violations, violations of laws, mismanagement, waste of College resources, and abuse of authority.

A representative of Gustavus shall not take or refuse to take any employment action in retaliation against an employee or applicant who reports possible misconduct under this policy in good faith, or who, following such disclosure, seeks a remedy provided under this policy or any law or College policy. However, employees or applicants who knowingly file false or misleading reports, or without a reasonable belief as to truth or accuracy, will not be protected by this policy, and in the case of an employee, may be subject to discipline, including termination of employment.

Process for Disclosure

1. An employee or applicant shall disclose all relevant information regarding evidenced misconduct to the President or his/her designee in a signed written document within ninety (90) days of the day on which he or she first knew of the misconduct. If the employee or applicant would rather contact a source outside of the College, he or she may contact the confidential Campus Conduct Hotline service as established by the College (866-943-5787).
2. The President or his/her designee shall consider the disclosure and take whatever action he or she determines to be appropriate under the law and circumstances of the disclosure.
3. In the case of disclosure of misconduct involving the President, the disclosure shall be directed to the Chair of the Board of Trustees. The Chair shall consider the disclosure and take whatever action he or she determines to be appropriate under the law and circumstances of the disclosure.
4. The disclosure recipient will be responsible for:
   1. Ensuring all investigations are carried out in a fair and unbiased manner.
   2. Ensuring that those making complaints and/or reporting compliance concerns are treated fairly, their confidentiality is protected to the extent the law allows, and no retaliation takes place.

Complaints of Retaliation as a Result of Disclosure

1. If an employee or applicant believes that he or she has been retaliated against in the form of adverse employment action for reporting possible misconduct under this policy, he or she may file a written complaint requesting an appropriate remedy.
2. For purposes of this policy, an adverse employment action shall be defined as actions including: discharge, demotion, suspension, being threatened or harassed, or in any other manner discriminated against with respect to compensation, terms, conditions or privileges of employment. This policy does not prohibit an employment action that would have been taken regardless of a disclosure of information.

Process for Adjudication of Complaints Stemming from Disclosure

1. An employee or applicant must file a complaint with the President or his/her designee with ninety (90) days from the effective date of the adverse employment action or from the date on which the employee or applicant should reasonably have had knowledge of the adverse employment action.
2. Complaints shall be filed in writing and shall include:
   1. Name and address of the complainant;
   2. Name and title of the College’s official(s) against whom the complaint is made;
   3. The specific type(s) of adverse employment action(s) taken;
   4. The specific date(s) on which the adverse employment action(s) were taken;
   5. A clear and concise statement of the facts that form the basis of the complaint;
   6. A clear and concise statement of the complainant’s explanation of how his or her report of possible misconduct is related to the adverse employment actions; and
   7. A clear and concise statement of the remedy sought by the complainant.
3. Within sixty (60) calendar days of receipt of complaint, the President or his/her designee (or the Chair of the Board of Trustees of Gustavus Adolphus College in the case involving the President) shall consider the written complaint, shall conduct or have conducted an investigation which, in his or her judgment, is consistent with the circumstances of the complaint and disclosure, and shall report to the complainant the conclusions of the investigation absent overriding legal or public interest reasons. The identity of the complainant and the subject of the compliant shall be kept confidential to the extent possible within the legitimate needs of law and the investigation.
4. The determination shall be in writing and shall include the findings of fact, the conclusions of the investigation, and if applicable, a specific and timely remedy consistent with the findings. The decision of the President or Chair of the Board of Trustees shall be final.

False Allegations of Wrongful Conduct

Any employee who knowingly makes false allegations of alleged wrongful conduct shall be subject to discipline, up to and including termination of employment, in accordance with College rules, policies and procedures.

Policy is Not a Contract

This policy is not a contract and it can be modified at any time, with or without notice. It does not provide greater or lesser rights than applicable law provides.

Approved by the Gustavus Adolphus College Board of Trustees: June 21, 2009.

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Gustavus Adolphus College aspires to be a community of persons from diverse backgrounds who respect and affirm the dignity of all people, where mutual respect, courtesy, kindness, and cooperation prevails. As such, and consistent with our core values and responsibilities, respect for each individual is central to how we conduct our work and build relationships within our community. Behavior that fails to respect the dignity of others is not compatible with this shared vision of our identity and our mission.

The policy of Gustavus Adolphus College is that every employee has the right to work and every student has the right to study and live in an environment free from unlawful discrimination, harassment, and other unwelcome behaviors that cause harm to another individual or group.

To Whom This Policy Applies

This Policy applies to all Gustavus students, employees (including faculty and staff) and volunteers. This Policy pertains to acts of prohibited conduct committed by students or employees when:

• The conduct occurs on College grounds or other property owned or controlled by the college; or
• The conduct occurs in the context of a College-sponsored employment, education program, or other activity, including, but not limited to, College-sponsored study away, research, online, or in internship programs; or
• The conduct occurs outside the context of a College employment or education program or activity, but has continuing adverse effects on or creates a hostile environment for students, employees, or third parties while on College grounds or other property owned or controlled by the College or in any college employment or education program or activity.

The College will also take appropriate steps to remedy situations when students or employees are the subject of harassment by third parties on College grounds or associated with the College. 

Prohibited Conduct Under This Policy

Gustavus, in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this Policy in accordance with the following definitions and guidelines: 

Discrimination: Gustavus prohibits discrimination on the basis of actual or perceived race, color, ethnicity, creed, religion, national origin, ancestry, citizenship status, age, sex or gender (including pregnancy, childbirth and pregnancy-related conditions), gender identity or expression (including transgender status), sexual orientation, marital status, familial status, military service and veteran status, physical or mental disability, genetic information, status with regard to public assistance, local human rights commission activity, or any other characteristic protected by applicable federal, state, or local law (“Protected Characteristics”) with regards to all aspects of an individual’s employment (recruiting, hiring, placement, promotion, transfer, training, compensation) and access to educational opportunities.

• Discriminatory behavior is behavior that involves biased treatment of an individual or group based upon their characteristics (see aforementioned list). 
• Some examples of discriminatory behaviors include:
  • Hiring practices that exclude an individual or group due their protected characteristics
  • Compensation practices that favor an individual or group due to their protected characteristics
  • Grading practices that favor an individual or group due to their protected characteristics

“Discrimination” may also include sex discrimination, and such prohibitions are addressed under the College’s Sex Discrimination Policy (under Title IX) (https://gustavus.edu/facultybook/allcollegepolicies/#con).

Harassment: The College will not tolerate harassment of any member of the College community based on that member’s Protected Characteristics. “Harassment” consists of unwelcome or offensive conduct, whether verbal, physical, or visual, that is based on a protected group status. The College will not tolerate harassing conduct that:

1. Affects tangible job or academic benefits;
2. Interferes unreasonably with an employee’s work performance or a student’s academic progress or success;
3. Creates an intimidating, hostile, or offensive environment.

Such harassment may include, for example:

1. Epithets, slurs, or negative stereotypes;
2. Intimidating or hostile acts based upon protected classification;
3. Written or graphic material that denigrates or shows hostility or aversion to persons of a protected classification and that is posted or circulated on College property.

“Harassment” may also include sexual harassment or sexual misconduct, and such prohibitions are addressed under the College’s Sex Discrimination Policy (under Title IX) (https://gustavus.edu/facultybook/allcollegepolicies/#con).

Bullying. Bullying involves aggressive, typically repetitive, and often deliberate behavior which imparts physical, mental, or emotional harm to a person or group through intimidation, coercion, force, hurtful teasing, threat, abuse, or causing discomfort. These types of bullying behaviors will not be tolerated. The College encourages constructive and thought-provoking dialogue and seeks to promote the open exchange of ideas and the independent pursuit of learning. The prohibition against bullying is not intended to prohibit individuals from raising concerns, either collectively or individually to College leadership, or individuals in leadership positions, and is not intended to create a “civility code” on campus. 

• In some cases, but not all, bullying may also rise to a level that is deemed unlawful harassment or discrimination. In other cases, bullying may be based upon differences not protected by law (e.g., body size, socioeconomic class, political affiliation, etc.), yet still work to undermine an individual’s sense of belonging at the College.
• Bullying can occur as a single, severe incident or repeated incidents, has the purpose or effect of unreasonably causing harm to, interfering with or sabotaging an individual's work or academic performance, reputation, and/or career, and may manifest itself in a form including, but not limited to, the following:
• Physical bullying includes pushing, shoving, kicking, poking, and/or tripping another; assaulting or threatening a physical assault; damaging a person’s work area or personal property; and/or damaging or destroying a person’s work/academic product. 
• Verbal and written bullying can come in the form of slandering, ridiculing, insulting or maligning a person or their family; persistent name calling that is hurtful, insulting or humiliating; abusive, threatening, derogatory or offensive remarks to a person; demeaning or dismissing an individual’s academic work due to disciplinary or sub-disciplinary area; and/or attempting to exploit an individual’s known intellectual or physical vulnerabilities. 
• Nonverbal bullying includes directing threatening gestures toward a person; invading personal space after being asked to move or step away; continual disrespectful facial expressions and glances that may convey a threatening message. 
• Cyber bullying is defined as bullying an individual using electronic forms, including, but not limited to, the Internet, interactive and digital technologies, or mobile phones.
• Bullying does not include, for example:
• A supervisor addressing unsatisfactory job performance; or
• Employee concerted activity protected under the National Labor Relations Act; or
• A professor addressing unsatisfactory academic performance.

Reporting and Addressing a Suspected Violation

If a member of the campus community believes he or she has experienced or witnessed a violation of this Policy, he or she should contact one of the following:

Human Resources Department, 507-933-6075
Office of the Provost, 507-933-7541
Office of the Dean of Students, 507-933-7526

While, generally, students will report concerns to the Dean of Students, faculty will report concerns to the Office of the Provost, and staff will report concerns to the Office of Human Resources, all three avenues are available to any member of the campus community.

The complaint should be as detailed as possible so that the College may take appropriate steps to look into the facts and circumstances of all claims of a perceived violation of this Policy. The College reserves the right to enforce this Policy related to off-campus behavior when affiliated with a college-sponsored event and/or circumstances that are related to other on-campus conduct.

The College will take prompt and appropriate steps to both investigate the allegations and implement a remedy, as appropriate, when a complaint is made. An investigation may range anywhere from a simple fact-finding inquiry to a formalized exploration process involving an external investigator. The timeline for the College actions will be governed by the complexity of the matter, including the time of year when the complaint is brought forward. The investigation and remedial steps will vary depending on the circumstances of the complaint.

Such steps may include: facilitating an informal resolution between the parties, making interim accommodations where applicable, redirecting the complaint to another policy/procedure at the college, conducting an internal investigation, or bringing in an outside third-party to assist with investigating the allegations. Each situation is unique, and the College retains discretion to determine how best to proceed under the circumstances:

• Title IX: If the allegation is based on sex discrimination, gender or sexual harassment or sexual misconduct, the College will review the initial complaint and make a determination as to whether the allegations meet the definition of Sex Discrimination Policy (under Title IX) and, if so, will proceed under the Sex Discrimination Policy for conducting an investigation.
• Accused Faculty Members: When a formal investigation warranted and completed, and the fact-finding report is shared with the Provost, if the Office of the Provost concludes that a faculty member’s alleged conduct justifies a minor sanction or may be sufficiently grave to merit a major sanction, the Office of the Provost will initiate proceedings outlined in the Faculty Manual (Section 3.2.4) (https://gustavus.edu/facultybook/).
• Accused Staff, Volunteer, or other Non-Faculty Personnel: The Office of Human Resources will determine if an investigation is warranted, and if so, the method of investigation, the manner in which a complaint will be addressed, and the level of applicable progressive discipline to apply to bring the complaint to resolution.
• Accused Students: The Office of the Dean of Students will utilize the College Student Conduct Procedures (https://gustavus.edu/deanofstudents/policies/gustieguide/) to bring a complaint to resolution. The College reserves the right to invoke the College Student Conduct System for student behavior occurring off-campus.

No Retaliation

See the College’s Retaliation Policy (https://gustavus.edu/facultybook/allcollegepolicies/#con).

Gustavus is committed to enforcing this Policy against all forms of unlawful harassment, unlawful discrimination, and other allegations under this Policy. However, the effectiveness of the College’s efforts depends largely on employees, students, and other members of the campus community to report inappropriate workplace and campus conduct. If a member of our campus community feels that they or someone else may have been subjected to conduct that violates this Policy, they should report it immediately. If individuals do not report discriminating, harassing, bullying or other unwelcome misconduct, the College may not become aware of a possible violation of this Policy, and appropriate corrective action cannot be taken.

Approved by the President’s Cabinet: April 16, 2013; updated August 14, 2018; revised and approved by the Gustavus Adolphus College Board of Trustees: October 7, 2022; updated October 11, 2024.

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Minnesota Statute

Subdivision 1. Definitions. (a) “Hazing” means committing an act against a student, or coercing a student into committing an act, that creates a substantial risk of harm to a person in order for the student to be initiated into or affiliated with a student organization.

(b) “Student organization” means a group, club, or organization having students as its primary members or participants.

Introduction

From a legal perspective, hazing is a crime. From an individual student’s perspective, hazing damages the self-esteem of those being hazed. From an organizational perspective, hazing degrades the values of the organization. From a campus community perspective, hazing creates an environment of disrespect that contradicts the College’s values of excellence, community, justice, service, and faith in our community. For all these reasons, the College takes a strong position against any and all forms of hazing.

Hazing is typically understood to be activity in which high-status group members require or suggest that members engage to join or continue affiliation with the group. Individuals, organizations and groups affected by this policy are expected to take primary responsibility for implementing the policy and for periodically reviewing their activities with respect to compliance with it. Officers and members of the organization may be held individually responsible for violation.

College Policy

Gustavus Adolphus College does not tolerate hazing in any form by any individual, group, or organization. Hazing is defined as any action taken or situation created, intentionally or unintentionally, whether on or off campus premises, to produce mental or physical discomfort, fatigue, humiliation, intimidation, embarrassment, harassment or ridicule or that disrupts community life or academic commitments regardless of the intent or end result. Such actions may be perpetrated by an individual, group, or organization against an individual or individuals.

This list of examples is not exhaustive because many things can be hazing or non-hazing activities depending upon the context and many other factors.

• Break laws or college policies
• Compromise personal morals or values
• Endure physical abuse or harm
• Endure psychological abuse or harm, such as deception of members which is designed to convince a member that s/he will not be accepted to the organization or that s/he will be hurt during the activity
• Submit to abuse of power or power differential
• Undergo branding, tattooing, or any mutilation of the skin
• Have substances thrown at, poured on, or otherwise applied to the body
• Consume alcohol, drugs, food or beverages
• Undergo exposure to the environment without appropriate dress
• Exercise that serves no purpose (e.g. calisthenics)
• Undergo physical detention, kidnapping, being held against one’s will, or abandonment
• Perform or participate in dangerous, degrading, or embarrassing public stunts, dares, displays, games, or activities
• Undergo prevention or deprivation of sleep, normal amounts of food or water, or adequate study time
• Perform an excessive number of tasks such that they encroach upon time needed for sleeping, studying, and attending to personal matters
• Participate in activities that interfere with scheduled class meetings, study sessions, or school-sponsored extracurricular activities
• Wear uncomfortable or inappropriate apparel or otherwise alter appearance which is conspicuous and/or atypical
• Experience public degradation
• Experience verbal harassment (such as degrading nicknames, derogatory references, yelling or screaming)
• Create or use explicit songs or perform sexist or racist acts
• Assume a submissive role
• Perform acts of personal servitude (such as cleaning, buying gifts, or making meals)
• Make excessive purchases (such as gifts, food, and clothing)
• Implementing ambiguous rules that serve no purpose, including but not limited to:
  • Keep silent or refrain from visiting non-group members
  • Not permitting members to talk for extended amounts of time
  • Carrying items for any period of time
• Having members line up to report facts, count off, or perform other unnecessary acts
• Learn trivia about members and about the group; ask members to learn chapter history or information if such a request interferes with academic study

Hazing can take place with or without the consent of the hazed. The consent of those hazed will not be accepted as a justification for hazing activities. Apathy or acquiescence in the presence of hazing are not neutral acts.

Consequences

Gustavus Adolphus College takes violations against the college hazing policy very seriously. Individuals, groups, and organizations are held accountable for acts of hazing. Furthermore, the College will treat the hazing action of even one member of a group as constituting hazing by the group. Those found responsible for hazing may be subject to severe sanctions including suspension or expulsion of the individual, group, or organization from the College.

Additionally, anyone who knew or who reasonably should have known of the hazing and did not make an attempt to prevent it may be adjudicated through the College’s conduct system. Every member of the campus community is required to report any incidents of hazing or suspicions of hazing that come to their attention.

Reporting

Campus community members are expected to report any practice or action believed to constitute hazing immediately. Reports may be made 24 hours a day to the Dean of Students (507-933-7526) or Campus Safety (507-933-8888). The college will not tolerate harassment of or retaliation towards individuals who have reported hazing incidents and will investigate any allegations of hazing that are reported.

Adopted Fall 2005; Revised Spring 2014. Updated and approved by the Executive Leadership Team October 29, 2024.

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Within the limits of its facilities, the College shall be open to all applicants who are qualified according to its admission requirements.

1. The College shall make clear to all applicants the characteristics and expectations of students that it considers relevant to its program.
2. Under no circumstances may an applicant be denied admission or financial aid because of race, color, creed, religion, age, sex, sexual orientation, national origin, marital status, disability, veteran status, status with regard to public assistance or other categories protected by federal, state or local anti-discrimination laws.
3. Financial aid administered by the College shall be disbursed on the basis of financial need and academic promise and/or academic ability.

Approved by the Gustavus Adolphus College Board of Trustees: June 21, 2009.

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Gustavus Adolphus College expressly prohibits retaliation against any individuals who make complaints (e.g. discrimination) against the College, their witnesses, supporters, and any advisors regardless of the outcome of the complaint. If a member of the campus community believes that he or she is experiencing retaliation, the individual may pursue a grievance through the Office of the Ombudsperson, Human Resources, Dean of Students, Academic Dean, or other appropriate senior supervisor, as appropriate.

Approved by the Administrative Council July 15, 1999.

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I. Introduction

Members of Gustavus Adolphus College (“Gustavus” or the “College”) community, guests and visitors have the right to be free from all forms of Sex Discrimination. All members of the campus community are expected to conduct themselves in a manner that does not infringe upon the rights of others. The College will not tolerate any violation of this Policy. 

This Policy outlines the College’s community expectations to ensure a campus free from Sex Discrimination, the steps for recourse for those individuals who have been subject to Sex Discrimination, and the procedures for determining whether a violation of College policy has occurred. This Policy applies to the following forms of Sex Discrimination: Non-Harassment Discrimination (Differential Treatment, Retaliation, and Failure to Provide a Student Reasonable Modifications for Pregnancy and Related Conditions) and Sex-Based Harassment (Quid Pro Quo Harassment, Hostile Environment Harassment, Sexual Assault, Domestic Violence, Dating Violence, Stalking, and Sexual Exploitation), as those terms are defined in this Policy. For the College’s nondiscrimination policy regarding other protected class statuses, see the All-College Policy on Non-Discrimination, Harassment, and Other Unwelcome Misconduct. Where the content of this Policy conflicts with other similar policies set forth in the student and/or Faculty and Employee handbooks, the requirements of this Policy shall prevail. 

This Policy supersedes any previous policies regarding sex discrimination, sexual misconduct and/or retaliation under Title IX and will be reviewed and updated, as needed, by the Title IX Coordinator. The College reserves the right to make changes to this document as necessary, and once those changes are posted online, they are in effect, and shall be applicable immediately to faculty, staff, and students, with or without notice. If government laws or regulations change, or court decisions alter, the requirements in a way that impacts this document, this document will be construed to comply with the most recent government regulations or holdings.

II. Notice of Non-Discrimination

 In accordance with applicable federal and state laws, such as Titles VI and VII of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, the Age Discrimination in Employment Act, and the Americans with Disabilities Act and ADA Amendments, the College does not unlawfully discriminate on the basis of sex, race, color, national origin, religion, age, disability, marital status, genetic information, veteran status, citizenship status, ancestry, or any other protected status under federal, state or local law applicable to the College, in its education programs and activities, in employment policies and practices, and all other areas of the College.

Sex discrimination is prohibited by Title IX of the Education Amendments of 1972, a federal law that provides that: “No person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.” The College is required by Title IX and its regulations not to engage in sex discrimination in its education program or activity, including admissions and employment. Sex discrimination is conduct based upon an individual’s sex, including on the basis of sex stereotypes, sex characteristics, pregnancy or related conditions, sexual orientation, and gender identity, that excludes an individual from participation in, denies the individual the benefits of, or treats the individual less favorably in an education program or activity. Sex-Based Harassment is a form of sex discrimination. In accordance with Title IX and its regulations, the College’s Title IX Policy addresses the College’s prohibition of the following forms of sex discrimination: Non-Harassment Discrimination (Differential Treatment, Retaliation, and Failure to Provide a Student Reasonable Modifications for Pregnancy and Related Conditions) and Sex-Based Harassment (Quid Pro Quo Harassment, Hostile Environment Harassment, Sexual Assault, Domestic Violence, Dating Violence, Stalking, and Sexual Exploitation). 

The College prohibits unlawful sex discrimination in any form. The College will promptly and equitably respond to all reports of Sex Discrimination. To report information about conduct that may constitute Sex Discrimination or to make a complaint of Sex Discrimination, please contact the Title IX Coordinator. 

Questions or concerns about Title IX and/or Sex Discrimination, including Sex-Based Harassment, may be directed to the College’s Title IX Coordinator: 

Amy Pehrson 
Title IX Coordinator 
Gustavus Adolphus College
Campus Center, 201A 
800 W. College Ave
Saint Peter, MN 56082 
507-933-6360 
titleix@gustavus.edu

Questions or concerns regarding Section 504 compliance may also be directed to the College’s Title IX Coordinator in her role as Assistant Dean of Students.

Questions or concerns may also be directed to the U.S. Department of Education’s Office for Civil Rights: 

The Office of Civil Rights 
U.S. Department of Education 
400 Maryland Avenue, SW 
Washington, DC 20202-1100 
Telephone: (800) 421-3481 
Facsimile: (202) 453-6012 
Email: OCR@ed.gov 
http://www.ed.gov/ocr 

III. Scope

 This Policy applies to all College community members, including but not limited to, students, employees, faculty, administrators, staff, applicants for admission or employment, and third parties, such as trustees, volunteers, vendors, independent contractors, visitors, and any individuals or entities that do business with the College or are regularly or temporarily employed, studying, living, visiting, conducting business or having any official capacity with the College or on College property. This Policy may also apply to individuals who interact with College community members under certain circumstances. All College community members are required to follow College policies and local, state, and federal law. 

This Policy applies to Sex Discrimination committed by or against a College community member, including conduct occurring on campus or College property, conduct that occurs at College-sanctioned events or programs that take place off campus, such as study abroad and internships, and off campus conduct that may (1) have continuing adverse effects on campus, College property, or in a College program or activity, (2) substantially and unreasonably interfere with a community member’s employment, education or environment on campus, College property, or in a College program or activity, or (3) create a hostile environment for community members on campus, College property, or in a College program or activity.

This Policy applies regardless of the sexual orientation or gender identity of any of the parties. 

IV. Title IX Coordinator and Title IX Team
The Title IX Coordinator is responsible for the coordination of the College’s Title IX compliance efforts, including the College’s efforts to end Sex Discrimination, prevent its recurrence, and address its effects. The Title IX Coordinator oversees and monitors the College’s overall compliance with Title IX-related policies and developments and the administration of this Policy; the implementation of complaint resolution processes, including investigation and adjudication of complaints of Sex Discrimination; the provision of educational materials and training for the campus community; and all other aspects of the College’s Title IX compliance. These responsibilities include, but are not limited to: 

• Coordinating specific actions to prevent Sex Discrimination and ensure equal access to the College’s education program or activity; 
• Ensuring College policies and procedures and relevant state and federal laws are followed; 
• Informing any individual, including a complainant, a respondent or another individual, about the procedural options and processes used by the College and about resources available at the College and in the community; 
• Monitoring the College’s education program or activity for barriers to reporting information about conduct that reasonably may constitute Sex Discrimination and taking steps reasonably calculated to address such barriers; 
• Training and assisting College employees regarding how to respond appropriately to a report of Sex Discrimination; 
• Monitoring full compliance with all procedural requirements and time frames outlined in this Policy;
• Evaluating allegations of bias or conflict of interest relating to this Policy; 
• Determining whether grounds for appeal under this Policy have been stated; 
• Ensuring that appropriate training, prevention and education efforts, and periodic reviews of the College’s climate and culture take place; 
• Coordinating the College’s efforts to identify and address any patterns or systemic problems revealed by reports and complaints;
• Recordkeeping of all incidents reported to the Title IX Coordinator;
• Complying with written notice requirements of the Violence Against Women Act; and 
• Assisting in answering any other questions related to this Policy.

Questions regarding this Policy should be directed to the Title IX Coordinator:

Amy Pehrson 
Title IX Coordinator 
Gustavus Adolphus College 
Campus Center, 201A 
800 W. College Ave 
Saint Peter, MN 56082 
507-933-6360 
titleix@gustavus.edu 

The College’s Title IX Team includes appointed staff and faculty designees. These team members have a shared responsibility for consulting with, and supporting, the Title IX Coordinator and may serve as the Title IX Coordinator’s designee. When this Policy refers to actions of the Title IX Coordinator, these actions may be fulfilled by the Title IX Coordinator or the Title IX Coordinator’s designee. Members of the team may also be called upon to investigate or adjudicate complaints of Sex Discrimination, decide appeals, and/or facilitate informal resolutions. The Title IX Coordinator has authority to consult with each individual appointed to serve in a role in the complaint resolution process to ensure compliance with the law and this Policy and to promote consistency in the College’s processes.

The Title IX team includes but is not limited to the Deputy Title IX Coordinators: 

• Tommy Valentini 
  507-933-6446 
  tvalentini@gustavus.edu 
• Martin Lang 
  507-933-6899 
  mlang3@gustavus.edu 

The College also reserves the right to outsource actions under this Policy to third parties, including actions of the Title IX Coordinator, investigator, decisionmaker, and appeal board. 

View the Full Policy

Approved by the President’s Cabinet: April 16, 2013. Updated and approved by the Board of Trustees: April 20, 2018, August 12, 2020, February 12, 2021, and October 11, 2024. This version revised and effective August 1, 2024.

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Policy

This conflict of interest policy is designed to help officers and employees of Gustavus Adolphus College (“the College”) identify situations that present potential conflicts of interest and to provide the College with a procedure which, if observed, will allow a transaction to be treated as valid and binding even though an officer or employee has or may have a conflict of interest with respect to the transaction. The policy is intended to comply with the procedure prescribed in Minnesota Statutes, Section 317A.255, governing conflicts of interest for nonprofit corporations. In the event that there is an inconsistency between the requirements and procedures prescribed herein and those in section 317A.255, the statute shall control. All capitalized terms are defined in Part 2 of this policy.

Guidelines

1. Conflict of Interest Defined. For purposes of this policy, the following circumstances shall be deemed to create Conflicts of Interest:
   1. Outside Interests.
      1. A Contract or Transaction between the College and a Responsible Person or Family Member.
      2. A Contract or Transaction between the College and an entity in which a Responsible Person or Family Member has a Material Financial Interest or of which such person is a trustee, officer, agent, partner, associate, trustee, personal representative, receiver, guardian, custodian, conservator or other legal representative.
   2. Outside Activities.
      1. A Responsible Person competing with the College in the rendering of services or in any other Contract or Transaction with a third party.
      2. Responsible Persons having a Material Financial Interest in; or serving as a trustee, officer, employee, agent, partner, associate, trustee, personal representative, receiver, guardian, custodian, conservator or other legal representative of, or consultant to; an entity or individual that competes with the College in the provision of services or in any other Contract or Transaction with a third party.
   3. Gifts, Gratuities and Entertainment. A Responsible Person accepting gifts, entertainment or other favors from any individual or entity that:
      1. does or is seeking to do business with, or is a competitor of the College; or
      2. has received, is receiving or is seeking to receive a loan or grant, or to secure other financial commitments from the College;
      3. is a charitable organization operating in Minnesota;
      4. under circumstances where it might be inferred that such action was intended to influence or possibly would influence the Responsible Person in the performance of his or her duties. This does not preclude the acceptance of items of nominal or insignificant value or entertainment of nominal or insignificant value that are not related to any particular transaction or activity of the College.
2. Definitions.
   1. A "Conflict of Interest" is any circumstance described in Part 1 of this Policy.
   2. A "Responsible Person" is any person serving as an officer or employee of the College.
   3. A "Family Member" is a spouse, domestic partner, parent, child or spouse of a child, brother, sister, or spouse of a brother or sister, of a Responsible Person.
   4. A "Material Financial Interest" in an entity is a financial interest of any kind, which, in view of all the circumstances, is substantial enough that it would, or reasonably could, affect a Responsible Person’s or Family Member’s judgment with respect to transactions to which the entity is a party. This includes all forms of compensation.
   5. A "Contract or Transaction" is any agreement or relationship involving the sale or purchase of goods, services, or rights of any kind, the providing or receipt of a loan or grant, the establishment of any other type of pecuniary relationship, or review of a charitable organization by the College. The making of a gift to the College is not a Contract or Transaction.
3. Procedures.

   Responsible Persons who are not members of the Board of Trustees of the College, or who have a Conflict of Interest with respect to a Contract or Transaction that is not the subject of Board or committee action, shall disclose to the Chair or the Chair’s designee any Conflict of Interest that such Responsible Person has with respect to a Contract or Transaction. Such disclosure shall be made as soon as the Conflict of Interest is known to the Responsible Person. The Responsible Person shall refrain from any action that may affect the College’s participation in such Contract or Transaction. In the event it is not entirely clear that a Conflict of Interest exists, the individual with the potential conflict shall disclose the circumstances to the Chair or the Chair’s designee, who shall determine whether there exists a Conflict of Interest that is subject to this policy.

4. Confidentiality.

   Each Responsible Person shall exercise care not to disclose confidential information acquired in connection with such status or information the disclosure of which might be adverse to the interests of the College. Furthermore, a Responsible Person shall not disclose or use information relating to the business of the College for the personal profit or advantage of the Responsible Person or a Family Member.

5. Review of Policy.
   1. Each new Responsible Person shall be required to review a copy of this policy and to acknowledge in writing that he or she has done so.
   2. Each Responsible Person shall annually complete a disclosure form identifying any relationships, positions or circumstances in which the Responsible Person is involved that he or she believes could contribute to a Conflict of Interest arising. Such relationships, positions or circumstances might include service as a trustee of or consultant to a nonprofit organization, or ownership of a business that might provide goods or services to the College. Any such information regarding business interests of a Responsible Person or a Family Member shall be treated as confidential and shall generally be made available only to the Chair, the President, and any committee appointed to address Conflicts of Interest, except to the extent additional disclosure is necessary in connection with the implementation of this Policy.
   3. This policy shall be reviewed annually by the Board of Trustees. Any changes to the policy shall be communicated immediately to all Responsible Persons.

Approved by the Gustavus Adolphus College Board of Trustees: June 21, 2009.

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Gustavus Adolphus College is committed to ensuring that personnel and other institutional decisions affecting present or prospective faculty, staff, administrators, or students be made fairly and impartially. Faculty, staff, administrators, and students frequently participate in personnel and other institutional decisions by serving on advisory committees. With respect to employees, the recommendations of such committees affect such matters as hiring, retention, promotion, and (with respect to faculty) tenure. In the case of students, such recommendations significantly affect admission to, or continued matriculation at, the College.

All members of the Gustavus community participating in such advisory committees must exercise integrity and objectivity when making decisions. Committee members must be certain that conflicts of interest or other biases do not exist which may interfere with their ability to make an impartial decision. A conflict of interest or bias occurs when a committee member has a financial or personal relationship or interest which impairs the member's ability to be fair and impartial. For example, a conflict of interest may well exist where a committee member will receive an individual financial benefit from a decision or where a committee member has a familial or similar relationship with an individual who may be affected by a decision.

A person serving on a committee may conclude that he or she has an actual (or perceived) conflict of interest or bias and may remove himself or herself from involvement in a particular decision to be made by the committee. A committee member who is not certain whether a conflict of interest or bias exists may bring his or her concern about the conflict or bias to the attention of the appropriate dean, committee chair, or supervisor; in this event, the committee member must disclose enough information to enable the dean, committee chair, or supervisor to consider the matter fairly and openly. If the dean, committee chair, or supervisor determines either that a conflict of interest or other bias (or the appearance of a conflict of interest or other bias) may exist, the committee member shall be excused from participating in making that decision.

A member of the committee or an individual who is the subject of a decision to be made by the committee may also raise a question as to whether a committee member has a conflict of interest or bias which may interfere with that committee member's impartiality. The concerned individual shall bring the matter to the attention of the appropriate dean, committee chair, or supervisor. The dean, committee chair, or supervisor shall discuss the matter with the affected committee member; if the dean, committee chair, or supervisor determines that a conflict of interest or other bias (or the appearance of a conflict of interest or other bias) may exist, the member of the committee shall be excused from participating in making the decision at issue.

A member of a committee who is excused from participating in making a decision in accordance with this policy does not forfeit his or her position as a member of the committee. The fact that an individual has been excused from participation pursuant to this policy shall not prejudice any personnel or other institutional decision made with respect to the committee member.

Adopted by the Gustavus Adolphus College Board of Trustees: January 17, 1994.

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1. Introduction

Federal regulations require the disclosure of Significant Financial Interests (SFI) from all Investigators upon submission of a proposal for funding to any Public Health Service (PHS) entity, which includes the National Institutes of Health (NIH), and prior to expenditure of any funds under an award from the National Science Foundation (NSF). Gustavus Adolphus College (the College) is responsible for determining whether any SFI represents a Financial Conflict of Interest (FCOI) and managing such conflicts.

It is the policy of the College to require Investigators seeking external funding from any government entity, or any other entity that has implemented these federal standards, to disclose SFI that reasonably appear to be related to their institutional responsibilities when applying for grant funds, as well as during the award period.

2. Definitions

Investigator refers to any person who is responsible for the design, conduct or reporting of research or educational activities funded or proposed for funding. In this context the term “Investigator” includes the Investigator’s spouse and dependent children.

A significant financial interest consists of financial interests that reasonably appear to be related to the investigator’s institutional responsibilities:

a) with regard to any publicly traded entity, a SFI exists if the remuneration received in the 12 months preceding the disclosure, and the value of any equity interest as of the date of disclosure, exceeds $5,000. “Remuneration” includes (i) salary, and any payments for services such as consulting fees or honoraria, paid authorship, reimbursed or sponsored travel and (ii) equity interest includes any stock, stock option, or other ownership interest.
b) with regard to any non-publicly traded entity, a SFI exists if the value of any remuneration received in the 12 months preceding the disclosure, and the value of any equity interest as of the date of disclosure, exceeds $5,000, or when the investigator holds any equity interest.
c) intellectual property rights and interests such as patents or copyrights, upon receipt of income related to such rights and interests.

An investigator also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of and not reimbursed to the investigator so that the exact monetary value may not be readily available) related to their institutional responsibilities, provided, however, that this disclosure requirement does not apply to travel that is reimbursed or sponsored by excluded sources provided in the federal regulation.

Significant financial interest does not include:

1. salary, royalties, or other remuneration paid by the institution to the investigator if the investigator is currently employed or appointed by the Institution;
2. intellectual property rights assigned to the institution and agreements to share in royalties related to such rights;
3. income from seminars, lectures, teaching engagements, or service on advisory committees or review panels sponsored by a governmental agency, an Institution of higher education, or a research institute affiliated with a higher education Institution.

A Financial Conflict of Interest exists if SFI could directly and significantly affect the design, conduct, or reporting on federally-funded research.

3. Policy

Disclosure of Significant Financial Interests

Each Investigator who is planning to participate in a federally funded project must complete the Disclosure of Significant Financial Interests form and attach required supporting documentation. This form must be completed and submitted to Research and Sponsored Programs by the time a proposal is submitted. Investigators are required to update their financial disclosures within thirty (30) days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) any new Significant Financial Interest; and, if awarded, annually by the anniversary date of any identified FCOI.

Collaborators

Any collaborator who can be defined as Investigator must either comply with Gustavus policies or certify to the College that their institution has policies that are in compliance with applicable regulations and agree to provide associated documentation.

Review of Financial Disclosures and Management of Financial Conflicts of Interest

The Director of Research and Sponsored Programs will review all financial disclosures reported by each Investigator and, in consultation with the External Funding Advisory Council and, as needed, others with relevant expertise, determine whether a conflict of interest exists. If a determination is made that a conflict of interest exists, the Director of Research and Sponsored Programs, in consultation with the External Funding Advisory Council, other experts as needed, and the Investigator, will determine what actions should be taken by the College to manage, reduce or eliminate any identified conflict of interest.

Conditions or restrictions that might be imposed by the College to manage, reduce or eliminate actual or potential conflicts of interest include:

• Public disclosure of Significant Financial Interests;
• Monitoring of research by independent reviewers;
• Modification of the research plan;
• Disqualification from participation in the portion of the funded research that would be affected by the Significant Financial Interests;
• Divestiture of Significant Financial Interests; or
• Severance of the relationships that create actual or potential conflicts.

To address complex situations, oversight committees may be established by the Director of Research and Sponsored Programs to periodically review the ongoing activity, to monitor the conduct of the activity, to ensure open and timely dissemination of the research results, and otherwise oversee compliance with the College’s imposed management plan.

Training

Investigators funded by PHS entities must complete training related to this policy:

• prior to engaging in research;
• at least every four years thereafter; and
• immediately, if:
  o the College amends the policy,
  o an Investigator is new to the College, or
  o an Investigator is not in compliance with the policy or management plan.

Investigators should consult with the Director of Research and Sponsored Programs about training options accepted by the College.

Reporting

The College will follow reporting guidelines set forth in the regulations of the federal funding agency. For example, all FCOI will be reported to the PHS sponsoring agency within 60 days of the original disclosure. The College will make information concerning FCOIs held by Investigators publically accessible as required by federal regulations.

Non-Compliance

Sanctions for non-compliance with the requirement to disclose Significant Financial Interests will be:

• notice of non-compliance with Gustavus policy placed in the employee’s permanent personnel file;
• employee will be barred from seeking external funding for a period up to 2 years; and
• employee will be ineligible for internal grants for a period up to 2 years.

Additional sanctions may be imposed, depending upon circumstances.

Sanctions for non-compliance with any management plan put in place for a Financial Conflict of Interest will be:

• notice of non-compliance with Gustavus policy placed in the employee’s permanent personnel file;
• employee will be barred from seeking external funding for a period up to 2 years;
• employee will be ineligible for internal grants for a period up to 2 years;
• notification of non-compliance sent to the sponsoring agency as required; and
• termination of the award.

Additional sanctions may be imposed, depending upon circumstances. In such cases, the Director of Research and Sponsored Programs and the External Funding Advisory Council will submit recommended sanctions to appropriate members of Cabinet for approval.

Records

Research and Sponsored Programs shall maintain records of all financial disclosures, completed trainings, and of all actions to resolve conflicts of interest for at least three years beyond the close of the grant, or until the resolution of any action involving those records, whichever is longer.

Approved by the President's Cabinet: November 27, 2018.

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When a death occurs in an employee’s immediate family, all regular full-time and part-time employees may take up to three (3) days off with pay, commensurate and prorated with the employee’s work schedule, to attend the funeral or make funeral arrangements. Please make arrangements with your supervisor regarding days off. Immediate family members are defined as an employee’s spouse, domestic partner, parents, stepparents, sisters, brothers, children, stepchildren, grandparents, father-in-law, mother-in-law, brother-in-law, sister-in-law, son-in-law, daughter-in-law, legal guardian, or grandchild. Gustavus understands the deep impact that death can have on an individual or a family, therefore additional non-paid time off may be granted upon supervisor approval.

Approved by the President's Cabinet: September 5, 2017.

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(See also the Parental Leave Policy)

Under the provisions of the Family and Medical Leave Act (FMLA) the College provides eligible employees with up to 12 weeks of unpaid leave in a 12-month period for the purpose of birth, adoption, or foster care placement; medical care of a child, spouse, or parent, or when the employee has a serious health problem. Gustavus Adolphus College also reserves the right to run FMLA concurrently with absences falling under Workers Compensation.

The College administers a “rolling” 12-month period measured backward from the date of any FMLA leave usage. (Each time an employee takes FMLA leave, the remaining leave is the balance of the 12 weeks not used during the 12 months immediately before the FMLA leave is to start.) 

To be eligible for an FMLA leave, an employee must have been employed for a total of 12 months and must have worked at least 1250 hours during the 12-month period preceding the commencement of the leave. Employees exempt from overtime requirements of the Fair Labor Standards Act are presumed to have worked the required hours unless the College clearly demonstrates that the employee did not work the required amount during the preceding 12 months.

The College will require a medical certification to support requests for a medical leave. For an employee's own medical leave, the certification must include a statement that the employee is unable to perform the functions of his or her position. In cases of illness, the employee may be required to report periodically on his or her leave status and intention to return to work, and may require periodic recertification of the medical condition. An employee taking leave due to the employee's serious health condition is required to obtain certification that the employee is able to resume work prior to the return from the medical leave. For leave to care for the medical needs of a child, spouse, or parent, the certification must include an estimate of the amount of time the employee is needed to provide care.

Employees who have paid leave available may be required to use their paid leave during a FMLA leave.

Any employee who is granted a FMLA leave is advised to provide for the retention of his or her group insurance coverage by arranging to pay the premium contributions during a period of unpaid absence. In the event that an employee elects not to return to work upon completion of an approved unpaid leave of absence, the College may recover from the employee the cost of any payments made to maintain the employee's coverage, unless the failure to return to work was for reasons beyond the employee's control. Paid leave accruals will be calculated as of the last paid work day prior to the start of the unpaid leave of absence.

A request for Family and Medical Leave of Absence should be originated by the employee and communicated to their immediate supervisor and the Human Resources department. If possible, the form should be submitted 30 days in advance of the effective date of the leave. All agreements on the leave, including extensions, should be in writing. Upon return to work at the end of the leave, the employee will be reinstated to the same or a comparable position without loss of status, pay, or accrued benefits.

Revised by the Gustavus Adolphus College Board of Trustees: January 21, 2021.

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Gustavus Adolphus College is committed to supporting faculty and staff in managing their professional and parental responsibilities. A primary goal of the parental leave policy is to allow both the faculty or staff member and the College the opportunity to maintain the integrity of the classroom and supporting services while avoiding an undue burden on either the individual or the department. All provisions and applications of this policy are meant to be consistent with federal and state law and the Family and Medical Leave Act (FMLA).

Eligibility

Full-time employees, part-time employees who have worked an average of 20 hours or more per week for 12 months, and part-time faculty employed for at least 12 months preceding the commencement of a parental leave, are eligible for six weeks of paid parental leave for maternity, paternity, or adoption. If a female employee needs a leave longer than six weeks due to medical complications of pregnancy and/or childbirth, she has the right to additional paid leave on the same basis as others with temporary health-related disabilities.

Terms and Conditions

Under the provisions of the Family and Medical Leave Act (FMLA), the College provides eligible employees with up to six weeks of paid leave and an additional six weeks of unpaid leave for the purpose of birth, adoption, or foster care placement; medical care of a child, spouse, or parent, or when the employee has a serious health problem.

Parental Leave may be completed anytime within a twelve-month period following the birth or adoption. Parental Leave will run concurrently with leaves available under the FMLA and Minnesota Parental Leave Law. An employee who has already used FMLA leave for purposes other than birth or adoption may be eligible for up to six weeks of unpaid leave.

Parental leave shall count as time in service toward salary determination and eligibility for sabbatical leave. The College’s contribution for health, disability and life insurance premiums shall be paid in full during all parental leave arrangements. Retirement benefits will be proportionate to salary or wages earned.

Application Process

A request for Parental Leave of Absence should be originated and signed by the employee as soon as the need for a leave is identified, submitted to the immediate supervisor or chair, and forwarded through the appropriate Vice President or Dean to the Human Resources Department. All agreements on the leave, including extensions, should be in writing. Upon return to work at the end of the leave, the employee will be reinstated to the same or a comparable position without loss of status, pay, or accrued benefits.

Faculty members should refer to the additional policies below.

Terms and Conditions

Eligible faculty members who welcome a child in the summer may take leave anytime within nine months of the resumption of their contract period to be arranged with the department and the Provost’s Office. Parental Leave will run concurrently with leaves available under the FMLA and Minnesota Parental Leave Law. A faculty member, who has used FMLA leave for purposes other than birth or adoption, may be eligible for up to six weeks of unpaid leave.

The Faculty Manual governs the timing of tenure decisions.

Menu of Possible Options

The following is a sample of several past parental leave arrangements with full benefits. This list is not comprehensive, nor is it guaranteed that all of these past arrangements will be possible in every instance. The Provost’s Office recognizes that circumstances may necessitate arrangements not covered by this list; faculty should work with their Department Chair and Dean to develop a mutually agreeable leave plan.

• six weeks paid and an additional 6 weeks unpaid
• one semester leave at 2/3 salary
• one course release at full salary
• combination of one course release and shifting remaining course load to January or a different semester at full salary
• teaching courses on an accelerated schedule at full salary (must be approved by the AOC)
• co-teaching courses that will allow the faculty member going on leave to be absent for a portion of those courses
• six weeks paid leave and administrative duties for the remainder of the semester
• intermittent leave arrangements

Adopted by the Gustavus Adolphus College Board of Trustees: April 24, 2015.

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Purpose of Policy

Computers and other information technology resources are essential tools in accomplishing the work of the College. Information technology resources are valuable community assets to be used and managed responsibly to ensure their integrity, confidentiality, and availability for appropriate research, education, outreach, and administrative objectives of Gustavus. College employees are granted access to these resources in support of advancing the College’s mission. This policy is constructed in a way to allow for complete academic freedom to exist, as outlined in the Faculty Manual Appendix A, while maintaining the integrity of the college’s technology resources. In the use of technology resources, College employees must follow College policies and federal, state and local laws. These include but are not limited to policies and laws related to information security, data privacy, commercial use, and those that prohibit harassment, theft, copyright and licensing infringement, and unlawful intrusion and unethical conduct.

Owner(s)

Director of Gustavus Technology Services and CFO, VP of Finance and Treasurer, Provost and faculty, staff and students employed by Gustavus Adolphus College.

Scope

The purpose of this policy is to outline the acceptable use of technology resources at the College in order to comply with legal and contractual requirements, safeguard these resources, and protect the College against damaging legal consequences that could result from unacceptable use.

1.0 Acceptable Use

Technology resources provided by Gustavus Adolphus College are intended to be used for the work and activities directly associated with employment. In their use of technology resources, employees should respect the rights of other users, avoid actions that jeopardize the integrity and security of information technology resources, and comply with all pertinent licensing and legal requirements.

Employees must comply with applicable contractual agreements and licensing agreements.

Gustavus Technology Services will determine and authorize use of technology resources in collaboration with Gustavus Vice Presidents or designees. Employees must use only technology resources they are authorized to use and only in the manner and to the extent authorized. Ability to access information technology resources does not, by itself, imply authorization to do so.

Users are responsible for protecting their College-assigned accounts and authentication (e.g., password) from unauthorized use. User passwords should be unique, secure, and never shared with others, including other Gustavus Adolphus College users.

Employees are responsible for the content of their personal communications and may be subject to liability resulting from those communications. The College accepts no responsibility or liability for any personal or unauthorized use of its resources by employees. Employees should be aware that communications sent from Gustavus Adolphus College-owned devices or accounts could be construed as representing a College position.

Copyright

Copyright is a form of protection provided by the laws of the United States (title 17, U.S. Code) to the authors of original works of authorship including literary, dramatic, musical, artistic, and certain other intellectual works. This protection is available to both published and unpublished works. Employees should assume materials found on the Internet are copyrighted unless a disclaimer or waiver is expressly stated or the material that is clearly in the public domain (e.g. published before 1923 or a U.S. federal 43 document).

Some examples of copyright violations would include:

• Displaying pictures or graphics you have not created yourself.
• Offering sound recordings you have not produced yourself.
• Using programs to distribute copyrighted files.
• Placing any materials owned by others on your web page (or any other medium) without the expressed permission of the original owner.

Fair Use

In some circumstances the use of a copyrighted work may be considered a 'fair use.' For more information see:

• https://www.copyright.gov/fair-use/more-info.html
• http://cmsimpact.org/program/fair-use/
• https://www.lib.umn.edu/copyright/fairthoughts

2.0 Unacceptable Use

Employees are not permitted to share authentication details or provide access to their College accounts to anyone else.

Employees must not circumvent, attempt to circumvent, or assist another in circumventing the security controls in place to protect information technology resources and data.

Employees must not knowingly download or install software onto College information technology resources which may interfere with or disrupt service, or does not have a clear business or academic use.

Employees are prohibited from willingly engaging in activities that interfere with or disrupt network users, equipment or service; intentionally distribute viruses or other malicious code; or install software, applications, or hardware that permits unauthorized access to information technology resources.

Employees must not engage in inappropriate use, including but not limited to:

• Activities that violate state or federal laws, regulations or College policies.
• Widespread dissemination of unsolicited and unauthorized electronic communications.

Employees must avoid excessive use of system information technology, including but not limited to network capacity.

Excessive use means use that is disproportionate to that of other users, or is unrelated to academic or employment-related needs, or that interferes with other authorized uses. Individual divisions within the College (e.g., academic affairs) may require employees to limit or refrain from certain activities in accordance with this provision.

Gustavus discourages the installation of personal software and files on College technology resources that are not directly associated with the work and activities of the College. Gustavus Technology Services is unable to support any personally installed software unrelated to work and activities of the College. Gustavus Technology Services assumes no obligation to transfer or retain any personally licensed software, personal files, or other non-college information or materials.

3.0 Privacy and Security Measures

Employees must not violate the privacy of other technology users. Technical ability to access others’ accounts does not by itself imply authorization to do so.

The College takes reasonable measures to protect the privacy of its information technology resources and accounts assigned to individuals. However, the College does not guarantee absolute security and privacy. Users should be aware that any activity on information technology resources may be monitored, logged and reviewed by College-approved personnel, or may be discovered in legal proceedings. Circumstances under which such review and discovery may occur are described immediately below.

Responsibility for protecting the College's resources and data is a shared responsibility by all employees and Gustavus Technology Services. Gustavus Technology Services treats the contents of individual assigned accounts and personal communications as private and does not examine or disclose the content except:

• as required for system maintenance, including security measures;
• when there exists reason to believe an individual is violating the law or College policy; and/or
• as permitted by applicable policy or law.

Before disclosing the contents of individual files or reassigning the ownership of a user’s account, GTS is required to receive authorization from two Gustavus Vice Presidents that a credible reason exists to take this action.

Employees may add additional measures for protection of information if required by grants or research agreements. If additional protection is added to College technology resources, system administrators must be given access to those resources upon request.

Employees should ensure the security and confidentiality of Gustavus’ data and student information. Student records are subject to heightened confidentiality requirements through legislation such as the Family Educational Rights and Privacy Act (FERPA). College-owned computers are issued with software tools that encrypt data stored on the machines; employees should not disable these tools. When sharing confidential and protected data, all employees should do so using a secure method approved by the College. Confidential Gustavus data or student records should not be created, downloaded or saved to any device in an unprotected format.

The College reserves the right to employ security measures. When it becomes aware of violations, either through routine system administration activities or from a complaint, it is the College's responsibility to investigate as needed or directed, and to take necessary actions to protect its resources and/or to provide information relevant to an investigation.

4.0 Enforcement

Individuals who use information technology resources to violate a College policy, law(s), contractual agreement(s), or violate an individual’s rights, may be subject to limitation or termination of user privileges and appropriate disciplinary action, legal action, or both. Alleged violations will be referred to the appropriate College office or law enforcement agency.

The College may temporarily deny access to information technology resources if it appears necessary to protect the integrity, security, or continued operation of these resources, or to protect itself from liability.

Help with this Policy

Contact the Director of Gustavus Technology Services for questions and comments on this policy.

Policy Authority

The Director of Gustavus Technology Services has responsibility for this policy and will obtain necessary approvals and changes to this policy.

Related Policies or References

Administrative and Support Staff Handbook; All College Policies.

Approved by the President's Cabinet: August 29, 2017.

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Earned Sick and Safe Time (ESST) is paid leave provided to employees that can be used for reasons related to illness of themselves or a family member, to seek assistance related to domestic violence for themselves or a family member, and for all other purposes outlined in this policy. All Gustavus Adolphus College employees who work at least 80 hours in a year in Minnesota are eligible for ESST.

Covered Uses

Employees can use ESST for:

1. the employee’s mental or physical illness, treatment, or preventive care
2. a family member’s mental or physical illness, treatment, or preventive care
3. absence due to domestic abuse, sexual assault or stalking of the employee or a family member
4. closure of the employee’s workplace due to weather or public emergency or closure of a family member’s school or care facility due to weather or public emergency
5. when determined by a health authority or health care professional that the employee or family member is at risk of infecting others with a communicable disease
6. Effective January 1, 2025, to make arrangements for or attend funeral services or a memorial, or address financial or legal matters that arise after the death of a family member

Employees may use earned sick and safe time for their following family members:

1. their child: including foster child, adult child, legal ward, child for whom the employee is legal guardian or child to whom the employee stands or stood in loco parentis (in place of a parent)
2. their spouse or registered domestic partners registered with the State of Minnesota
3. their sibling, stepsibling, or foster sibling
4. their biological, adoptive or foster parent, stepparent or a person who stood in loco parentis (in place of a parent) when the employee was a minor child
5. their grandchild, foster grandchild or step-grandchild
6. their grandparent or step-grandparent
7. a child of a sibling of the employee
8. a sibling of the parents of the employee
9. a child-in-law or sibling-in-law
10. any of the family members listed in 1 through 9 above of an employee’s spouse or registered domestic partner
11. any other individual related by blood or whose close association with the employee is the equivalent of a family relationship
12. up to one individual annually designated by the employee

Use, Accrual, and Carryover

Accrual begins at the start of employment. Employees may use available paid sick and safe time as it accrues. Employees can use leave in 15-minutes increments.

All eligible employees accrue one hour of ESST for every 30 hours worked, up to a maximum of 48 hours each year. For non-exempt (hourly) employees who are also eligible for PTO and under the College’s policy, ESST accrual is part of PTO or vacation and not a separate portion of paid time off and will therefore follow PTO accrual rates and maximums.

Exempt (salaried) employees are presumed to work 40 hours in each workweek for purposes of accruing earned sick and safe time, except that an employee whose normal workweek is less than 40 hours will accrue earned sick and safe time based on the normal workweek. Exempt employees, and non-exempt employees ineligible for PTO, may carry over accrued, unused ESST leave into the following year, but the total amount of accrued, unused ESST leave may not exceed 80 hours. If/when an employee's bank of accrued ESST hits 80 hours, no further ESST will accrue unless and until the employee uses it such that the bank drops below 80 hours (at which point ESST will begin accruing again as normal, always subject to the 80-hour cap).

Notice and Documentation Requirements

If the need for leave is foreseeable, the employee must notify their supervisor/chair at least 7 days in advance. If the need for ESST is not foreseeable, the employee must follow the call-in procedure to notify their supervisor of their absence as soon as practicable. Employees should provide the reason for their absence or tardiness when calling it in so that ESST can be appropriately tracked. If an employee does not provide notice as soon as practicable (usually when calling in), the College reserves the right to deny ESST coverage, in accordance with applicable law.

If the employee uses ESST for more than three consecutive scheduled work days, the College may request reasonable documentation to verify the absence, such as from a health care provider, in accordance with applicable law. Any information disclosed as a result of using ESST time will be kept confidential and in accordance with the College’s policies and applicable law.

Other Forms of Time Off

Employees will still be entitled to other forms of leave such as Vacation, Holidays, FMLA, and Short-Term Disability, as applicable. ESST will be used in conjunction with other leaves when possible. Employees should contact the Office of Human Resources with questions.

Separation and Rehire

Accrued, unused ESST is not paid out upon separation of employment, for any reason.

Employees who are rehired within 180 days of separation will receive and be eligible to use all previously accrued but unused ESST. Employees who are rehired more than 180 days after separation shall begin accruing ESST as though a “new” employee.

No Retaliation

The College expressly prohibits any form of discipline, reprisal, intimidation, retaliation, or discrimination against any individual for requesting or taking ESST or filing a complaint or bringing a civil action for violations of this policy, or applicable state or local law.

The College is committed to enforcing this policy and prohibiting retaliation against employees who request or take ESST under this policy, or who file a related complaint. However, the effectiveness of the College’s efforts depends largely on individuals reporting inappropriate workplace conduct. If employees feel that they or someone else may have been subjected to conduct that violates this policy, they should report it immediately to their supervisor or the Office of Human Resources. If employees do not report retaliatory conduct, the College may not become aware of a possible violation of this policy and may not be able to take appropriate corrective action.

Approved by the President’s Executive Leadership Team: August 20, 2024; revised September 3, 2024. Approved by the Board of Trustees: October 11, 2024.

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As a recipient of federal funds, Gustavus Adolphus College must comply with the Office of Management and Budget’s 2 CFR 200 Uniform Guidance. This regulation provides guidance on the allowability of costs on federal awards and sets forth criteria for charging salaries and wages to grants. Under these federal guidelines, Gustavus must certify compensation on externally funded sponsored activities and document committed cost share.

To comply with these federal regulations, it is the policy of Gustavus Adolphus College to conduct compensation certification for all exempt employees participating in externally funded sponsored activities. Non-exempt employees, including students, certify their compensation by completing their payroll time entry and approval process.

Compensation Certification Process

Research and Sponsored Programs (RSP) will seek certification with Principal Investigators and Project Directors (PI/PDs) of externally funded sponsored programs no less than annually. It is the responsibility of the PI/PDs to monitor their grant budget postings in the College’s financial system.

PI/PDs are responsible for ensuring that any compensation charged to their externally funded sponsored program is allowable, allocable, and reasonable. PI/PDs will be asked to certify all individuals paid from their funded program worked in alignment with program objectives at least as much as they were paid, commensurate with the individual’s institutional base salary. When salary confidentiality is of concern, RSP or Finance can assist with this determination.

Any compensation outlined in a funding proposal will be provided to the Finance Office upon award. PI/PDs are responsible for communicating changes in planned compensation to RSP prior to the effective date of the change. Changes that are more than 120 days late will not be applied to sponsored funding. Compensation plans for those not identified in the proposal must be submitted to RSP prior to starting work.

Consequences of Non-Compliance

Inaccurate, late (90 days) or incomplete compensation certification may result in funding disallowances and lead to sanctions against the responsible PI/PDs. Sanctions for late submissions of compensation certification documents will be as follows:

• notice of non-compliance with Gustavus policy placed in the PI/PDs permanent personnel file;
• PI/PD will be barred from seeking external funding for a period up to 2 years; and
• PI/PD will be ineligible for internal grants for a period up to 2 years.

Additional sanctions may be imposed, depending upon circumstances.

This policy is effective beginning with FY24 processes, including AY23 certifications.

Approved by the Executive Leadership Team: August 15, 2023

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Background

Percentage of Time per Duties Assigned

As a matter of policy, Gustavus Adolphus has not historically established faculty contracts based on a percentage of work per duties assigned, while many other schools publish how much of a faculty’s member’s time should be spent on teaching, research, advising, service to the institution, and so forth. Instead, when faculty are evaluated and/or reappointed, the following are considered-in order of importance:

1. Excellence as a teacher
2. Emerging pattern of excellence in scholarship and/or creative pursuits
3. Emerging pattern of involvement with the college and its activities
4. Continuing evidence of sympathy with aim and purpose of the college
5. (Gustavus Adolphus College Faculty Manual)

Faculty Time and External Funding

Gustavus has a strong tradition of seeking and being awarded external funding through grants and contracts, whether that funding comes through government, private, or corporate sources. However, the college has not had a standard policy for charging faculty time for these grants. To compensate, individual faculty members have been devising formulas-based on their employment contracts-to charge for their time. This system is flawed in that it demands impeccable record keeping in order to understand budgets-and, by default, it accepts that some people’s time is “worth more” than others’.

As external compliance demands grow, it is essential that the College both adopt and follow a policy for charging for faculty time. This policy will help ensure that the process of applying for a grant is systematized, in that each faculty member’s time is considered of equal value relative to base salary. More importantly, a policy will ensure that all future grant and contract budgets can easily pass external audits.

It is important to note that no policy for charging faculty time is a perfect representation of how all faculty actually spend their time. Rather, a policy for charging faculty time is meant to be a representation across the institution: one that is reasonable and fair to both faculty and to external funders. Having taken these factors into consideration, the External Funding Advisory Council has created this aspirational policy that recognizes the College’s increasing emphasis on intellectual engagement, research, scholarship, creativity and dialogue as part of the new Gustavus Acts Strategic Plan (2016). This policy is but one representation of the value among Gustavus faculty to be active scholars who are committed to submitting highly competitive proposals for external funding.

Policy

Policy Understanding

• This policy covers all 9-month faculty contracts.
• This policy uses base salary in its calculations. Benefits must also be charged.
• This policy accounts for: 1) the variety of ways in which faculty actually use their time; 2) funders’ expectation that faculty are using a portion of their academic year time toward research and scholarship; and 3) the possibility of using this academic year time as a portion of any required match on external grant applications.
• Externally funded research, scholarship, and creative activities sometimes require a level of effort that does not fit within a faculty member’s typical academic year time allocations. All faculty requests for reassignment time as part of an application for external funds for research or other sponsored projects including grants, service agreements, contracts, and other similar agreements must follow this policy.

Policy for Charging for Faculty Time during the Academic Year - 70/20/10

When charging for faculty time on external grants and/or contracts, the College agrees to the following relative to how faculty time is spent:

• 70%: teaching and teaching–related activities. Percentage based on contractual six-course load per academic year.
• 20%: research, scholarship, and creative pursuits. This percentage is in line with the 8 hours per week that may be set aside on faculty schedules (May 2016 faculty meeting).
• 10%: service to the college. This percentage acknowledges that all faculty dedicate time to the institution through committee work and other service via their contract each year.

Since faculty load is six courses per academic year, reassignment time for one course is equivalent to 11.67% of a faculty member’s time, or base salary, for those on a nine-month contract (70%/6).

Examples:

• Faculty member A earns $60,000/year. The cost to buy out the salary portion of one course, then, is $7,002 (60,000 x .1167 (11.67%)) plus benefits.
• Faculty member B earns $80,000/year. The cost to buy out the salary portion of one course, then, is $9,336 (80,000 x .1167) plus benefits.

Policy for Charging Faculty Time during Summer

Summer appointments will be charged at a rate commensurate with the faculty member’s institutional base salary plus benefits.

Example:

• One summer month is equivalent to 1/9 of a faculty member’s academic year salary. Faculty member A earns $60,000/year. The cost for one summer month, then, is $6,667 (60,000/9) plus benefits.

Consult a Grants Office Director for release time equivalencies for faculty on appointments other than the 9-month term.

Procedure for Requesting Reassignment Time

Check sponsor guidelines to determine whether reassignment time is allowed. In some instances, a sponsor may need to approve a reassignment time prior to submission of a proposal. The Grants Offices can assist with interpreting sponsor guidelines prior to requesting reassignment time.

1. Discuss the proposed reassignment time with relevant Dean and Department Chair.
2. The Dean must approve the reassignment time by signing the Reassignment/Course Release Approval Form.
3. The Department Chair or designee must acknowledge the reassignment time, provide information regarding which course(s) would be removed from the faculty member’s load, and whether the department plans to remove the course(s) or offer the course(s) as an internal overload or external hire during the period of the grant. This information should be provided on the Reassignment/Course Release Approval Form and sent to the appropriate Grants Office no later than 7 business days prior to the submission deadline.
4. The grant budget must include a line item associated with the reassignment time, based on the faculty member’s salary and benefits, equivalent to the percentage of reassignment time requested. This budget must be reviewed by either the Director of Faculty Grants or the Director of Government, Corporate and Foundation Relations prior to submission of the package to the Provost’s Office for final approval.
5. The appropriate Grants Office will forward the Reassignment/Course Release Request Form, the proposal summary or abstract, and the budget to the Provost’s Office no later than 7 business days prior to the submission deadline.
6. Approval from the Provost’s Office, via signed Reassignment/Course Release Approval Form, must be submitted to the Grants Office no later than 3 business days prior to the sponsor’s submission deadline.

Approval is made on condition that the reassignment time is properly budgeted for and will only be granted if an award is made.

Salary Distribution Guidelines

Salary savings will be distributed as follows:

1. The Provost Office will receive funds to cover the costs for instruction of course(s) that will be offered during the faculty member’s release time, including salary and benefits (if applicable).
2. 15% of any remaining funds will be distributed to the College's unrestricted budget.

85% of any remaining funds will be distributed to the Provost’s Office to be used for activities related to strategic efforts to support research, scholarship and creative activities on campus, for example toward Presidential Faculty-Student Collaboration Grants or Capacity Building Grants. A faculty member may submit a proposal to the Provost’s Office requesting a portion of these funds be reallocated to their sponsored project or program.

Approved by the President’s Cabinet: March 28, 2017.

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Policy

Externally funded research, scholarship, and creative activities enhance the reputation of the College. It benefits both the careers of faculty and staff and the education of students who participate or are impacted by the externally funded work. These projects and programs incur both direct and indirect costs, the latter of which are recovered by applying a rate to the budget request portion of a funding proposal. This policy sets forth guidelines for requesting facilities and administrative (indirect) costs reimbursement on externally funded projects and programs. In the case of exceptions to full recovery, externally funded programs must budget administrative costs directly. This policy also outlines the method the College uses to distribute recovered indirect costs.

Background

Facilities and Administrative Costs (often referred to as indirect costs or F&A) are costs paid by agencies that enter into grant or contract agreements with Gustavus for research and other projects. They are provided to the College as a reimbursement for real costs incurred in maintaining the infrastructure for research and programming at a federally negotiated rate. This rate is reviewed by the Department of Health and Human Services every four years, and is published by Research and Sponsored Programs (RSP). Typically, indirect costs cannot be readily identified with a particular project. Examples of indirect costs include, but are not limited to: maintenance of physical facilities, depreciation of buildings, insurance, utilities, information technology, instrumentation, library expenses, and administrative staff.

Guidelines

It is the expectation of the College that all externally funded sponsored program budgets will include a request for reimbursement of indirect costs regardless of whether or not the sponsor is a federal entity, because there are real facilities and administrative costs associated with every project. While some exceptions apply, these exceptional instances are nearly exclusively due to policies of the external entity or funding source. Exceptions to application of the federally negotiated indirect cost rate:

• The sponsor has a published rate that is either lower than the College’s rate or a rate that is applied to an alternative base (e.g. 15% of total direct costs). This rate must appear in the sponsor’s written guidelines, published on their website, or confirmed in a letter from an authorized official. This rate must be uniformly applied to all entities seeking funding from that agency for the relevant funding opportunity.
• The program limits the indirect costs. A common example would be training grants issued by the US Department of Education.
• When an award is transferred to Gustavus Adolphus College from another institution and Gustavus’ indirect cost rate is higher than the rate at the previously awarded institution, the College will adjust the rate, as needed, so funds designated for direct costs in the original budget remain available to the project.

In instances where an award is made with an inaccurate budget, the PI/PD will be responsible for the unrecovered indirect costs.

Budgeting for Additional Administrative Costs

Submissions that do not recover indirect costs at the College’s full federally negotiated rate and meet at least one of the following criteria, are required to include budget support for administrative assistance in Research and Sponsored Programs. These criteria include:

• A sub-award from Gustavus
• Gustavus is the lead on a collaborative proposal involving non-Gustavus entities
• Commitment of match or other long-term sustainability commitments from the College
• Hiring of non-student personnel or staff/faculty reassignment time
• Includes an international scholarly component that requires travel outside of the US
• Includes international collaborators
• Award is for an amount equal to or larger than $300,000
• Multiple separate projects are included within one grant
• Training grants that include support for non-Gustavus participants

Proposals that meet at least one of the above criteria must budget 5% of total direct costs for Grant Administration in the personnel section of the budget along with full benefits for those wages. Exceptions may be granted by the Director of RSP for small short term grants, but will be only approved in exceptional circumstances.

Distributing Indirect Cost Recovery

Purpose

Indirect costs are recovered for previously incurred, already paid real costs. The College has the opportunity to use these funds strategically for incentives, operations, and capacity building for research.

Distribution of Funds from Awards Receiving the Full Federally Negotiated Rate

50% to General College Budget to offset current College expenses

15% to Principal Investigator as Incentive Funds which must be spent within one year of the grant end date. Funds may be spent in the following ways:

• Project-related costs not otherwise covered by the grant, including cost-share
• Equipment, materials, supplies, and fees directly related to the PI’s research or teaching
• Wages and benefits for faculty and students to conduct scholarly work or develop a course during the summer
• Travel expenses related to research, conference attendance/presentation for PI or students(s)
• Equipment maintenance
• Wages for students working during academic year and not receiving course credit
• Computer hardware and/or software associated with research (must be purchased through GTS)
• Up to one reassigned course per year, plus benefits, with prior Dean and Provost approval

35% to Provost’s Research Capacity Building Fund which must be spent within three years. Funds may be spent in the following ways:

• Support of Research and Sponsored Programs office (e.g. staffing, salary, benefits, professional development) to ensure high quality support for programs, research, scholarship, and creative activities at the College
• Additional support of externally funded programs (e.g. required cost share)
• Activities that will support submission of future external funding requests (e.g. internal grants)

Distribution of Funds for Indirect Costs Collected at a Reduced Rate

50% to General College Budget to offset current College expenses

50% to Provost’s Research Capacity Building Fund which must be spent within three years. Funds may be spent as outlined above.

Approved by the President’s Executive Leadership Team: November 7, 2023, Effective January 1, 2024

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Policy

Gustavus Adolphus College requires all students, as well as those with post-baccalaureate and post-doctoral research positions, who are conducting research paid for by local, state, or federal grant funds to complete training in the responsible conduct of research (RCR). Principal Investigators and Project Directors (PI/PD) are responsible for ensuring that these researchers who are working on their government funded projects complete all required trainings on time. The Director of the Office of Government Grants and Sponsored Programs serves as the RCR Administrator for Gustavus.

As part of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act, the National Science Foundation introduced RCR training requirements in 2010. Subsequently the United States Department of Agriculture and the National Institutes of Health have implemented training requirements. Though this Gustavus RCR policy meets and exceeds the standards of many government agencies, it does not meet the requirements of the National Institutes of Health. If a researcher is participating in NIH funded work, please consult the Director of Government Grants and Sponsored Programs to develop a compliant training plan.

Areas of training at Gustavus will include authorship, collaborative research, conflicts of interest, data management, mentoring, peer review, research misconduct, and plagiarism. Training for research involving animal care and use, and research involving human subjects is also required as relevant. Training is valid for four years, however refresher courses are recommended after three years. This training, as well as other trainings required by Gustavus such as lab safety training, are in place to protect the College, PI/PDs, students, and other employees conducting research at Gustavus.

Requirements

1. All relevant web-based training requirements must be met prior to beginning work on the government-funded project.

• Online RCR Course: All student, post-bac and post-doc researchers must complete an online Responsible Conduct of Research course. Instructions for completing this training can be found at https://gustavus.edu/grants/policies/.
• Human Subjects: Those conducting research involving human subjects must complete the supplemental online training module. Consult the Gustavus Institutional Review Board regarding any additional training requirements.
• Animal Subjects: Those conducting research with animals must complete the supplemental online training module. Consult Gustavus Institutional Animal Care and Use Committee regarding any additional training requirements.

2. In-person training must be completed either before the employment start date, or within the term the researcher begins work (January or spring semester, summer, fall semester). This training will be offered at least three times each calendar year. A training schedule can be found at https://gustavus.edu/grants/policies/.
3. Certificates or other documentation of training completion shall be provided to the PI/PD and the Director of Government Grants and Sponsored Programs within 7 days of finishing each training requirement.

Non-Compliance

If it is determined that a researcher has been working without completing the required trainings, the researcher faces possible suspension or termination of employment at Gustavus, and the PI/PD faces possible funding disallowances and sanctions. Notification of and sanctions associated with non-compliance will follow the timeline outlined below:

Within seven days of determination of Non-Compliance, the researcher and PI/PD will receive an email notification that proof of training has not been received, including the consequences of continued non-compliance with College policy.

If a researcher has been out of compliance for 14 days, the researcher and PI/PD will receive a warning email that formally outlines the sanctions associated with non-compliance with Gustavus policy. The relevant Dean or VP will be copied.

After 30 days or more of non-compliance, employment of the researcher will be suspended until the researcher is in compliance with College policy. The PI/PD will be required to discuss the circumstances surrounding the non-compliance with the relevant Dean/VP and the Director of Government Grants and Sponsored Programs. Within the subsequent seven days, the PI/PD will receive formal notification that details any funding disallowances and sanctions in effect upon receipt of the letter.

Sanctions will include:

• notice of non-compliance with Gustavus policy will be placed in the permanent personnel file of the PI/PD;
• the PI/PD will be barred from seeking external funding for a period up to 2 years; and
• the PI/PD will be ineligible for internal grants for a period up to 2 years.

Approved by the President’s Cabinet: August 21, 2017.

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At Gustavus Adolphus College, the Director of Corporate and Foundation Relations in Advancement (CFR) and the Director of Faculty Grants in the Office of Government Grants and Sponsored Programs (GGSP) are the College’s authorized representatives for the submission of proposals for external funding. The offices of GGSP and CFR are committed to facilitating the submission of highly competitive proposals that conform to government regulations, agency guidelines, and College policies. They work closely with Principal Investigators and Project Directors (PI/PD), assisting throughout the process of seeking and managing external funding – from the point of having an idea through to closing out the grant and submitting final reports. As part of this process, they review and submit proposals on behalf of the College, and facilitate the acceptance and management of awards for sponsored projects on behalf of the College in collaboration with the Offices of Finance, the Provost, Advancement, and the President.

All external funding proposals must be reviewed and approved by GGSP or CFR before submission to the external sponsor, or before submission of Gustavus’ materials to a collaborating institution for inclusion in their proposal to an external sponsor. This includes applications, pre-proposals, letters of intent, concept papers, contracts, subcontracts, and fellowships, regardless of funding source or whether funds are awarded to the College or to the individual. Prior to approving a submission, GGSP or CFR will review all proposal materials and assist with collecting internal approvals. At times GGSP or CFR may request changes to bring a proposal into compliance with guidelines and policies, or suggest changes that will enhance competitiveness. The signature of either the Director of GGSP or CFR on the required External Funding Approval Form certifies that commitments made on grants, contracts, and agreements can be honored, verifies the accuracy of information provided on grant proposals or contract agreements, and ensures that all sponsored agreements conform to relevant policies. When the proposal is complete and all approvals have been secured, GGSP or CFR submits the proposal or authorizes the PI/PD to submit the proposal to the sponsor.

Internal Deadlines for Proposal Review

The offices of GGSP and CFR can provide the highest level of service to faculty and staff when adequate lead time is given to review and approve a proposal prior to submission. The following timeline represents a minimum for GGSP or CFR to provide feedback and a thorough review of an application. A more detailed list of steps, along with other resources, can be found at www.gustavus.edu/grants. Remember your submission date might be the day your materials are due to a collaborator, not necessarily the grant deadline.

1. Discuss your idea with GGSP or CFR. Some projects will require internal vetting which will be required at least one month prior to the submission deadline. Longer lead times will be necessary if your project involves collaborators, institutional commitments or course reassignments, or is a limited submission opportunity, for example.

2. As soon as possible, at least 12 full working days prior to the planned submission date – Confirm timeline and plan upcoming submission with GGSP or CFR. This allows staff to allocate time for providing feedback and reviewing proposal components.

3. At least 7 full working days prior to the submission date – Provide GGSP or CFR with a project budget and budget justification, along with a draft version of the narrative that is suitable for review.

4. At least 3 full working days prior to the submission date – Provide GGSP or CFR with all final proposal documents and a completed External Funding Approval Form. Following a final review of the proposal GGSP or CFR will then submit the application or authorize the PI/PD to do so.

Late Submission to Internal Deadlines and Unauthorized Submissions

Proposals submitted after the internal deadlines will be processed on a first-come-first-served basis. Priority is given to complete proposals that are submitted on time and to proposals components submitted for review based on the agreed upon timelines. The PI/PD assumes the risk that late or incomplete proposals may not be approved for submission, may not meet external submission deadlines, or may be submitted without adequate review. Such a proposal may be withdrawn from funding consideration upon full review should it contain errors or lack internal approvals that would preclude Gustavus Adolphus College’s acceptance of an award.

When a proposal is submitted without review and approval by GGSP or CFR, the following consequences or repercussions may occur:

• If improperly budgeted, the PI/PD will be responsible for covering required budget components or any over spending that may result. These may be covered by a PI/PD via a department budget, via an unrestricted endowed line associated with the PI/PD, or via other means. If being paid by a Gustavus restricted or unrestricted fund, approval by the Provost’s Office is required for faculty PI/PDs and approval by the primary supervisor is required for staff or administrator PI/PDs.
• Award terms and conditions may preclude Gustavus from accepting the award.
• Unauthorized signatures or inadequate negotiation of award terms and conditions may render the award invalid and result in immediate termination of the project.
• The College and the PI may not be able to negotiate salary, benefits, leaves or other institutional commitments that were included in the proposal, thus resulting in declining or terminating an award.

Approved by the President’s Cabinet: November 8, 2016.

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Gustavus Adolphus College is concerned for the well-being of all members of its academic community and for the quality of their relationships. One area of that concern involves the use of alcohol and other drugs.

The College does not condone the use of alcohol when prohibited by law. On the contrary, it seeks to foster an atmosphere in which abstinence from alcohol is accepted, respected, and supported. The College also expects individuals and groups to make responsible choices with regard to alcohol use. Careful consideration must be given if alcoholic beverages are to be available at College-sponsored off-campus activities or events where underage individuals are present. While the alcohol and drug policy makes provisions for the consumption of alcohol in conjunction with some special events, participants should be able to participate in all activities planned. Activities with alcohol may segregate those not of legal age from those who are, and this could be counter-productive to the development of community.

The College takes the position that chemical abuse is neither socially nor morally acceptable. It also recognizes the reality of chemical dependency and is aware of its presence in the academic community. We are obliged to help those who could be harmed or inconvenienced as a result of the irresponsible behavior of others. As a part of encouraging responsible lifestyles, Gustavus will strive to provide education about alcohol and other drug use, to encourage responsible choices, and to intervene in situations where it has knowledge of individual misuse and abuse of chemicals.

The College will encourage and provide reasonable help for members of the community who seek treatment for chemical dependency.

The College expresses the following objectives with regard to alcohol and other drugs:

1. To support and encourage those who choose to abstain from the use of alcohol and other drugs.
2. To undertake to educate members of the College community regarding the effects of use, misuse, and abuse of alcohol and other drugs.
3. To formulate and maintain guidelines for appropriate response to the misuse and abuse of alcohol and other drugs.
4. To expect individuals who use alcohol to act responsibly and respect the rights, needs, and lifestyles of other members of the community.
5. To sensitize Collegiate Fellows, Head Residents, Peer Assistants, faculty, staff, and students to the implications of chemical use, and especially to the needs of those who misuse or abuse alcohol.
6. To provide direct assistance and/or referral for those with substance-abuse problems.

Each member of the community is encouraged to support the objectives of this policy. The Dean of Students shall have the primary responsibility for monitoring it for the student body, with primary enforcement provided by Safety and Security and the Residential Life staff. The Dean of Students shall continue to study, develop, and evaluate the program of education for the campus community dealing with the implications of alcohol and drug use. This policy shall be subject to periodic review by the Board of Trustees working together with students, faculty, and administrators for this purpose. Refer also to the Residential Life Policy section on "Alcohol and Other Drugs" for further information on the application of this policy for residence hall living.

Statement of Rules

Any violation of the following rules shall be considered an offense subject to disciplinary action by appropriate authorities. The College reserves the right to request assistance from law enforcement officials where State or local laws are being violated.

1. Minnesota law and college policy prohibit the possession or consumption of alcoholic beverages by persons under the age of 21. Providing alcohol to a minor, or assisting a minor in any way in obtaining alcohol, is specifically included as inappropriate behavior and is also a violation of State law.
2. Possession, use, sale or solicitation of illegal substances is prohibited.
3. State and local laws prohibit the purchase and resale of alcoholic beverages without a license. College policy prohibits the sale of alcoholic beverages on campus.
4. Promotion on campus (including, but not limited to circulars, posters, campus publications) of consumption of large amounts of alcohol, or of events where drinking is the primary focus, is prohibited.
5. Consuming or possessing alcohol in an open container in any public campus location is not permitted. The Gustavus Alcohol and Drug Policy allows the serving of alcoholic beverages on campus only under the following conditions:
   1. Designated areas shall be determined and reviewed by the appropriate Vice President or Dean, subject to approval by the President.
   2. The sponsor(s) must sign a request form detailing their event and indicating that they have received the statement: "Responsibilities of a Sponsor of a Social Event at which Alcoholic Beverages are Served."
   3. The request for use of a designated area must be submitted to the appropriate Vice President or Dean at least seven (7) days prior to the event.
   4. The event must be confined to the designated area.
   5. The event must be confined to the times listed on the application, and the type and amount of alcoholic beverage limited to what is specified beforehand. Non-alcoholic beverages must be continuously available in a similar manner as the specified alcoholic beverage for underage guests and those wishing to abstain.
   6. Serving of alcoholic beverages must be in conjunction with a reasonable amount of food.
   7. Those sponsoring the event are responsible for insuring that only those of legal age consume alcohol, and that consumption takes place in the designated area only.
   8. The sponsors will be responsible for returning the area to its prior condition.

For application forms or more information about the designated area policy, contact the Dean of Students Office.

Alcohol Policy revised and approved by the Board of Trustees, June 28, 1985; revised July 2, 1986, and July 21, 1987, to comply with changes in State law; revised and approved by the Board of Trustees, June 27, 1994.

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In accordance with the "Drug-Free Workplace Act of 1988" (Public Law No. 100-690, 5151-5160), effective March 18, 1989, Gustavus Adolphus College is hereby notifying its employees that the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited at Gustavus Adolphus College and in the course of any activities performed in conjunction with the employee's work-related responsibilities. Although the "Drug-Free Workplace Act" requires that only those employees "Directly engaged in the performance of work pursuant to the provisions of the federal grant or contract" abide by this policy, Gustavus Adolphus College has elected to include all employees under this policy.

(Controlled substances are defined in schedules I through V. of section 202 of the Controlled Substances Act (21 U.S.C. 812) and are further defined by the regulation at 21 DFR1300.11 through 1300.15). It is important to note that not only is the use of illegal drugs unlawful, but also the illegal dispensing of legal (prescription) drugs. Alcohol and tobacco are not included in this law.

As a condition of employment at Gustavus Adolphus College, all employees will abide by the terms of the College's "Drug-Free Workplace Policy" and will notify the College of any criminal drug statute conviction for a violation occurring in the workplace no later than five days after such conviction. Employees found in violation of the prohibitions set forth in the policy will be subject to disciplinary actions which may include suspension or dismissal.

Employees who are convicted of a violation in the workplace or while engaged in work-related responsibilities may be required to participate in a drug abuse assistance or rehabilitation program approved for such purposes by a federal, state, or local health, law enforcement, or other appropriate agency. Appropriate personnel action shall be taken against such convicted employee up to and including termination of employment within 30 days of receiving notice of conviction.

Employees are also urged to attend one of the drug-free awareness programs which will be available at different times throughout the year. Other parts of the drug-free program may include drug counseling and employee assistance programs.

Implemented: March 18, 1989. Reviewed by the Gustavus Adolphus College Board of Trustees: June 28, 1993.

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Purpose: The purpose of this policy is to promote the wellbeing and safety of Gustavus Adolphus College students, faculty, staff, and visitors and to protect the College’s property/assets. This policy is intended to provide clear guidelines for the allowance of pet/service animals on campus.

Scope: This policy applies to all on-campus, College-controlled properties, including the arboretum and all athletic facilities. This policy standardizes the College’s position on the management of animals on Gustavus property. Campus Safety is charged with enforcement of this policy.

Rationale: Pets can pose various health and safety risks to the campus community including allergic reactions to animal dander, excessive noise, discomfort around animals, fear of animal bites, and disease transmission. Individuals that require the use of a service animal are at particular risk. For example, a dog running at large poses a hazard to an individual using a service dog, should there be a confrontation between the two animals.

Definitions

1. College-Controlled Property: Property that is owned, operated, and/or maintained by the College.
2. Service Animal: trained animals that assist an individual with a disability by performing specific tasks. Service animals are allowed everywhere their handler needs to go on campus. Under the Americans with Disabilities Act and the Minnesota Human Rights Act, a service animal is defined as a dog or miniature horse. Service animals do not have to wear an identifying vest or patch, nor do their handlers need to register or make their presence known to staff.
3. Emotional support animals (ESA): animals that provide support, companionship, or comfort to an individual, but they are not specifically trained to perform tasks to assist an individual with a disability. Emotional support animals do not have the same broad legal protections service animals do, but the Fair Housing and Equal Opportunity Act allows an individual with a disability to request as a reasonable accommodation that their ESA reside with them in on-campus housing.
4. Working Emergency Personnel animals: St. Peter Police K-9s and other animals working on campus for emergency personnel will be treated as exemptions to the college pet policy when working with their handler.
5. Research and Teaching Animals: Approved animals used directly in support of the College’s mission of teaching, research, and/or clinical programs as used in accordance with guidelines established by the Office of the Provost and the Institutional Animal Care and Use Committee.
6. Pets at Large: An animal that is either unattended and/or unrestrained by its owner.

Inside/Outside Facility Guidelines

It is prohibited to bring dogs, cats, or other pets inside any College-controlled buildings, except for the animals listed in the exemption section of this policy. While on College-controlled properties, pets must be maintained on a leash of six feet or shorter, on a restraining harness, or in a caged enclosure. With the exception of the animals listed in the exemption section, pets are not allowed in the arboretum, or at/on any indoor or outdoor athletic facilities. Pets will not be allowed (leashed or unleashed) at any special events or College functions (e.g., Nobel Conference, Homecoming, athletic venues) with the exception of any specific event that has been approved 45 days in advance by the Vice President for Finance and Treasurer, who serves as the college’s officer for risk management issues.

Pet owners are responsible for cleaning up any messes made by their pet. Anyone who brings a pet on College-controlled property assumes all financial responsibility for any damages to property or injury to individuals caused by the animal.

Pets may not be tethered to College buildings, structures, motor vehicles, trees, railings, light poles, benches, posts, or other structures.

Prohibited Animals (Non-Service)

Animals such as poisonous reptiles, constricting snakes (e.g., boas, pythons, and anacondas) and other potentially dangerous or aggressive animals are prohibited from all College-controlled property (inside and outside) at all times, except those used for approved academic or experimental purposes.

Failure to Comply

1. Prohibited Animals on College-Controlled Property: Any prohibited animals on a College-controlled property must be removed immediately. If a prohibited animal is observed on a College-controlled property, the owner may face disciplinary measures by appropriate authorities, which may include Campus Safety, Residential Life, Provost, or Human Resources.
2. Unattended or Unrestrained Animals: If an unrestrained/unattended animal is observed, a reasonable attempt will be made to locate the animal’s owner. If the owner is located, they may face disciplinary measures by the appropriate disciplinary authorities (see above). If attempts to find the animal’s owner are unsuccessful, the animal will be relinquished to or removed by the City of Saint Peter Community Service /Animal Control Officer.
3. Property Damage: The College will seek restitution for any animal-related damage to College-controlled property, facilities, or grounds. The repair or replacement cost of damaged property is the sole responsibility of the owner of the animal that caused the damage.

Exempted Pets and Other Animals

The animals listed below are permitted inside College-controlled property:

1. Service animals.
2. Working emergency personnel animals.
3. Research and testing animals.
4. Fish in containers of fifteen (15) gallons or less.
5. Pets at/in the President’s House or residence hall professional staff apartments.
6. Emotional Support Animals (ESA): ESAs are only allowed in a student’s room, in direct transit to/from the student’s room to the building exit or outside on College grounds. ESAs are not allowed in the Arboretum nor in any other buildings on campus.

Although these aforementioned animals are permitted within all or some buildings and facilities, these animals must remain under the control of the owner at all times. The care or supervision of an exempted animal is solely the responsibility of its owner. The College reserves the right to exclude an exempted animal whose behavior poses a threat to the wellbeing or safety of others.

Cabinet Approved: February 2016. Revised August 23, 2022.

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The Gustavus Adolphus College Safety and Health Program is based on the premise that each and every one of our employees is entitled to a safe and healthful working environment. Our Safety and Health Program is designed specifically for the protection of our employees, the campus community and visitors. All employees are directed to make safety a matter equal in importance to that of other job functions.

The College shall have an active Safety and Health Committee with diverse area representation that meets regularly. All employee injuries and accidents will be reviewed by the committee with minutes available to all employees on the Environmental Health, Safety and Risk Management website. All employees are encouraged to make suggestions which will assist in maintaining safe working conditions and to immediately bring to the attention of their manager/supervisor any unsafe working conditions. It is through our joint participation in safety efforts that accidents and injuries can be prevented.

All employees, including faculty, staff and students, must follow the safe practices and rules contained in this document and any other such rules and procedures communicated on the job regarding employee safety and health during the course of employment. It is important that all employees maintain a safe workplace and always practice safe work habits. Working safely is a condition of employment.

Our policy toward safety is in no way limited to the rules that follow. Any unsafe practice, whether listed here or not, will be addressed. No job is so important that we cannot take time to perform our work safely.

1. EXPECTATIONS - Employees are expected and empowered to work safely and responsible for the safety of co-workers. If co-workers are observed working in an unsafe manner, employees must communicate their concerns to their co-workers and/or their supervisor/manager.
2. EMERGENCY PROCEDURES - Employees will fully understand all work area emergency procedures and participate in drills when requested. Supervisors/managers shall ensure that their employees are familiar with emergency notification systems, emergency contact numbers, evacuation routes, emergency equipment locations and assembly areas. 
3. INJURY REPORTING - All injuries and illnesses, no matter how slight, must be reported to the direct supervisor/manager of the employee so that arrangements can be made for medical or first aid treatment, if necessary. Any head, neck, eye or back injury must be evaluated by a medical provider. An accident/incident/illness report will be completed and submitted to Risk Management within 24 hours. Supervisors/managers will ensure that the injured employee provides updates on their work status and if they have any work restrictions defined by their medical provider in a report of workability prior to returning to work. Injury Reporting Procedures and the Injury Report Form can be found at the Environmental Health, Safety and Risk Management website.
4. HOUSEKEEPING - Good housekeeping must be practiced at all times in work areas and offices to prevent slips, trips and falls. Wastes must be cleaned up daily to eliminate any dangers in work areas. Notify the appropriate supervisor/manager immediately of any unsafe work areas. Exits, fire suppression equipment, emergency eyewash/showers, electrical panels, etc., must always be kept clear of obstructions in the event of an emergency.
5. PERSONAL PROTECTIVE EQUIPMENT (PPE) – PPE shall be worn whenever necessary and/or required. Inspect PPE prior to use and notify the appropriate supervisor/manager immediately of any defects. More information regarding PPE can be found at the Environmental Health, Safety and Risk Management website.
6. DRUGS & ALCOHOL - There will be absolutely no use of intoxicants or illegal drugs during working hours. Anyone suspected of being under the influence of intoxicants or illegal drugs, which may impair their skills and/or judgment, shall not be permitted on the job. Employees shall notify the appropriate supervisor/manager of prescription medications being taken that may affect job safety. No one shall be permitted to work while the employee’s ability or alertness is so impaired by fatigue, illness, and/or other causes that may cause injury to the employee, or others. For more information, refer to the Drug and Alcohol policy
7. VEHICLES - It is important for all drivers to recognize their responsibilities for operating Gustavus Adolphus College vehicles in a safe and responsible manner. We require each driver to comply with all applicable federal, state and local regulations, including Gustavus Adolphus College policies. When operating any vehicle for Gustavus Adolphus College business. The Vehicle Safety Policy and Vehicle Accident Report Form can be found at: [ Insert NEW Link ]
8. UNSAFE BEHAVIOR - Horseplay, scuffling, fighting, practical jokes, throwing tools or materials carelessly and other unsafe acts which have an adverse influence on employee safety, or the safety of others, is strictly prohibited.
9. TRAINING - All employees will participate in regular safety meetings and/or trainings when required. Safety-related training suggestions should be submitted to the appropriate supervisor/manager. 
10. PROPER LIFTING - Work shall be pre-planned to avoid injuries in the handling of heavy materials and use of equipment. Supervisors/managers shall encourage team lifts and the use of lift equipment. Always use proper lifting techniques when lifting heavy objects.
11. MACHINE GUARDING - Employees will ensure that all guards and other protective devices are in their proper places and in good working order. If the guard or protective device is not in place or defective, the equipment should not be used. Never use defective tools or equipment. Report damaged equipment to your supervisor/manager immediately. 
12. ELECTRICAL HAZARDS - Only authorized employees can work with electrical equipment or machinery and only after they have been trained in proper procedures and use of the equipment. Supervisors/managers shall ensure that employees receive proper training on this equipment.
13. SAFETY ORIENTATION - Employees will ensure they have received adequate safety instruction when undertaking a new task or using new or unfamiliar equipment. Supervisors/managers will ensure that their employees are properly trained.
14. CHEMICALS - When using any type of chemical, employees must fully know and understand:
    1. Safety Data Sheets and hazardous chemical properties (if any).
    2. Types of precautions required to work with chemicals in a safe manner.
    3. Proper Personal Protective Equipment needed to be worn.
    4. All emergency procedures.
15. FIRE PREVENTION - Observe all fire prevention regulations. The campus and all campus vehicles are tobacco free. Fire extinguishers that have been used or that have a broken seal must be turned in for replacement.
16. APPROPRIATE ATTIRE - Work clothing must be appropriate for the work area as to not present a safety hazard. Submit questions regarding proper attire to the appropriate supervisor/manager.
17. LOCKOUT/TAGOUT - Lockout/tagout all equipment before maintenance and/or repair. Supervisors/managers shall ensure that employees are properly trained.
18. ENFORCEMENT - Failure to follow established safety rules and procedures may lead to disciplinary procedures which may include: reprimand, suspension or employment termination.

More information regarding safety programs can be found on the Environmental Health, Safety and Risk Management website.

Approved by the President's Cabinet: November 9, 2021.

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As of July 1, 2018, Gustavus Adolphus College is a tobacco free college. Tobacco use is prohibited within all college campus grounds, college owned or leased properties, and in campus-owned, leased, or rented vehicles even when used outside campus grounds.

Tobacco products include but are not limited to cigarettes, cigars, pipes, water pipes (hookah), bidis, kreteks, smokeless tobacco, chewing tobacco, snus, snuff, electronic cigarettes and any non-FDA approved nicotine delivery device.

Approved by the Administrative Council: September 14, 1993. Reviewed by the Gustavus Adolphus College Board of Trustees: June 27, 1994. Revised by the President’s Cabinet: March 6, 2018.

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The personal possession of firearms in all campus buildings and on all campus property is strictly prohibited. This prohibition applies to all students, employees, independent contractors, and visitors, including those who have a valid permit to carry a concealed weapon. Individuals who possess a valid permit to carry a firearm may however, keep it locked in the trunk or glove compartment their vehicle in a campus parking lot. This prohibition does not apply to authorized security or law enforcement personnel. Individuals wishing to store firearms and ammunition at Gustavus can do so by bringing them to the Office of Safety and Security, Room 35A, Norelius Hall basement.

Except under circumstances noted above, students and employees are prohibited from using, storing or possessing weapons, fireworks or explosives on property owned or controlled by the College and/or in the course of any College program or employment. Weapons may include, but are not limited to: firearms, pellet guns, air rifles or BB guns, paintball guns, bows and arrows, sling shots, water balloon launchers, martial arts equipment, swords, switchblade and large knives, and clubs.

If you are aware that an individual possesses a firearm, or other weapon or explosives in violation of this policy, please contact Safety and Security (933-8888) immediately.

Approved by the Gustavus Adolphus College Board of Trustees: June 23, 1993.

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Gustavus Adolphus College accords its students all rights under The Family Educational Rights and Privacy Act (FERPA) of 1974, and will annually notify students and their parents of their rights pursuant to FERPA through notifications in the College Catalog, Gustavus Guide, and on WebAdvisor. The College will not disclose information from students’ education records without the written consent of students except to personnel within the institution, to officials of other institutions in which students seek to enroll, to persons or organizations providing students financial aid, to accrediting agencies carrying out their accreditation function, to persons in compliance with a judicial order, and to persons in an emergency in order to protect the health or safety of students or other persons.

At Gustavus only those persons acting in the students’ educational interest are allowed access to student education records. These include personnel in the offices of the Dean of Students, Provost, Registrar, Admission, Academic Support Center, Student Financial Assistance, Career Development, and to faculty members within the limitations of their need to know.

At its discretion, the institution may provide directory information in accordance with the provisions of the Act to include: student name, mailing address, email address, telephone number, date and place of birth, major field of study, dates of attendance, degrees and awards received, the most recent previous educational institution attended, participation in officially recognized activities and sports, and weight and height of members of athletic teams.

Students may withhold directory information by filing the appropriate form with the Registrar. This agreement of nondisclosure will remain in effect unless a written request is submitted to end the suppression.

Students may inspect their education records, challenge any contents, have hearing if the outcome of the challenge is unsatisfactory, and submit explanatory statements for inclusion in their files if they feel the decisions of the hearing panel are unsatisfactory.

Student education records at Gustavus are maintained in the offices of the Dean of Students, Registrar, Student Financial Assistance, and Career Development.

Students wishing to examine their education records must make written requests to the appropriate office listing the item or items of interest. Only records covered by the Act will be made available, within thirty days of the requests. Students may take notes of the record, but may not make copies or take photographs of their records.

Education records do not include records of instructional, administrative, and educational personnel which are the sole possession of the maker and are not accessible or revealed to any individual except a temporary substitute, records of the security department, student health records, employment records, or alumni records. Health records, however, may be reviewed by physicians of the students’ choosing.

Students may not inspect the following as outlined by the Act: financial information submitted by their parents; confidential letters and recommendations associated with admissions, employment, job placement, or honors to which they have waived their rights of inspection; or education records containing information about more than one student, in which case the College will permit access only to that part of the record which pertains to the inquiring student.

The College is not required to permit students to inspect and review confidential letters and recommendations placed in their files prior to January 1, 1975.

Students who believe that their education records contain information that is inaccurate or misleading may discuss the matter with the chief administrator of the office involved. If that person is in agreement with the students’ requests, the appropriate records will be amended. If not, the students will be notified within a reasonable period of time that the records will not be amended and be informed of their rights to a formal hearing.

Requests for a formal hearing must be made in writing to the Dean of Students who, within a reasonable period, will inform students of the date, place, and the time of the hearing. Students may present evidence relevant to the issues raised and may be assisted or represented at the hearing by one or more persons of their choice, including attorneys, at the students’ expense. The hearing panel will be comprised of the students’ faculty adviser, a representative of the Dean of Students, and the Provost.

Decisions of the hearing panel will be based solely on the evidence presented at the hearing, will consist of written statements summarizing the evidence and stating the reasons for the decisions, and will be delivered to all parties concerned. The education records will be corrected or amended in accordance with the decisions of the hearing panels, if the decisions are in favor of the students. If the decisions are unsatisfactory to the students, the students may place with the education records statements commenting on the information in the records, or statements setting forth any reasons for disagreeing with decisions of the hearing panels. The statements will be released whenever the records in question are disclosed.

Students who believe that their rights have been abridged, may file complaints with The Family Educational Rights Privacy Act Office (FERPA), Family Policy Compliance Office, Department of Education, Washington, D.C. 20201, concerning the alleged failures of Gustavus to comply with the Act.

Approved by the Gustavus Adolphus College Board of Trustees: June 28, 1993; revised September 26, 2019.

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Program Adoption

Gustavus Adolphus College (the “College”) developed this Identity Theft Prevention Program (the “Program”) pursuant to the Federal Trade Commission’s Red Flags Rule (the “Rule”), which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. This program was developed with oversight and approval of the Finance Committee of the Board of Trustees. In addition, the Board of Trustees determined that the Program was appropriate for the College, and approved this Program on April 24, 2009.

Purpose

The purpose of this policy is to establish a Program designed to detect, prevent and mitigate identity theft in connection with the opening of a covered account (defined below) or an existing covered account and to provide for continued administration of the Program. The Program shall include reasonable policies and procedures to:

1. Identify relevant red flags (defined below) for covered accounts it offers or maintains and incorporate those red flags into the program;
2. Detect red flags that have been incorporated into the Program;
3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
4. Ensure the Program is updated periodically to reflect changes in risks to students and to the safety and soundness of the creditor from identity theft.

The Program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.

Definitions

Identity theft means fraud committed or attempted using the identifying information of another person without authority.

A covered account means:

1. An account that a creditor offers or maintains, primarily used for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions.
2. A red flagmeans a pattern, practice or specific activity that indicates the possible existence of identity theft.

Covered Accounts

A covered account includes all student accounts or loans that are administered by the College or administered by a service provider.

Identification of Relevant Red Flags

The Program considers the following risk factors in identifying relevant red flags for covered accounts:

1. The types of covered accounts as noted above;
2. The methods provided to open covered accounts—acceptance to the College and enrollment in classes require some or all of the following information:
   1. Common application with personally identifying information
   2. High School Transcript
   3. Official ACT or SAT scores (required or optional)
   4. Two letters of recommendation
   5. Medical and insurance information
3. The methods provided to access covered accounts:
   1. Disbursement obtained in person requires picture identification
   2. Disbursement obtained by mail can only be mailed to an address on file
4. The College's previous history of identity theft.

The Program identifies the following red flags:

1. Documents provided for identification appear to have been altered or forged;
2. The photograph or physical description on the identification is not consistent with the appearance of the student presenting the identification;
3. A request made from a non-College issued E-mail account;
4. A request to mail something to an address not listed on file; and
5. Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts.

Detecting Red Flags

In order to detect red flags in connection with the opening of covered accounts and existing covered accounts, it is the policy of the College to:

1. Obtain identifying information about, and verify the identity of, a person opening a covered account, and
2. Authenticate covered account holders, monitor transactions, and verify the validity of change of address requests, in the case of existing covered accounts.

Responding to Detected Red Flags

The Program shall provide for appropriate responses to detected red flags to prevent and mitigate identity theft. The appropriate responses to the relevant red flags may include the following:

1. Deny access to the covered account until other information is available to eliminate the red flag;
2. Contact the student;
3. Change any passwords, security codes or other security devices that permit access to covered accounts;
4. Notify law enforcement; or
5. Determine no response is warranted under the particular circumstances.

Oversight of the Program

Responsibility for developing, implementing and updating this Program lies with the Vice President for Finance and Treasurer (the “Program Administrator”). The Program Administrator will be responsible for Program administration, for ensuring appropriate program-related training of College staff, and for reviewing any reports regarding the detection of Red Flags and the steps for preventing and mitigating Identity Theft, determining which steps of prevention and mitigation should be taken in particular circumstances and considering periodic changes to the Program.

Updating the Program

This Program will be periodically reviewed and updated to reflect changes in risks to students and the security of the College from identity theft. At least once per year in April, the Program Administrator will consider the College’s experiences with identity theft, changes in identity theft methods, changes in identity theft detection and prevention methods, changes in types of accounts the College maintains and changes in the College’s business arrangements with other entities. After considering these factors, the Program Administrator will determine whether changes to the Program, including the listing of Red flags, are warranted. If warranted, the Program Administrator will update the Program.

Staff Training

College staff responsible for implementing the Program shall be trained by the Program Administrator in the detection of Red Flags, and the responsible steps to be taken when a Red Flag is detected.

Oversight of Service Provider Arrangements

The College shall take steps to ensure that the activity of service providers is conducted in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft whenever the College engages a service provider to perform an activity in connection with one or more covered accounts.

Currently, the College uses Tuition Management Systems (a member of KeyBank National Association) to administer a tuition payment plan, and University Accounting Service LLC to administer the Perkins Loan program.

Approved by the Gustavus Adolphus College Board of Trustees: April 24, 2009.

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Gustavus Adolphus College (“the College”) takes seriously its obligations to preserve information relating to litigation, audits, and investigations. The information listed in the retention schedule below is intended as a guideline and may not contain all the records the College may be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the President. From time to time, the President may issue a notice, known as a “legal hold,” suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the President.

File Category	Item	Retention Period
Corporate Records	By-laws and Articles of Incorporation	Permanent
	Corporate resolutions	Permanent
	Board and committee meeting agendas and minutes	Permanent
	All-College Policies	Permanent
	Conflict-of-interest disclosure forms	4 years
Finance and Administration	Financial statements (audited)	Permanent
	Auditor management letters	7 years
	Payroll records	7 years
	Check register and checks	7 years
	Bank deposits and statements	7 years
	Chart of accounts	7 years
	General ledgers and journals (includes bank reconciliations)	7 years
	Investment performance reports	7 years
	Equipment files and maintenance records	7 years after disposition
	Contracts and agreements	7 years after all obligations end
	Correspondence — general	3 years
Insurance Records	Policies — occurrence type	Permanent
	Policies — claims-made type	Permanent
	Accident reports	7 years
	Safety (OSHA) reports	7 years
	Claims (after settlement)	7 years
	Group disability records	7 years after end of benefits
Real Estate	Deeds	Permanent
	Leases (expired)	7 years after all obligations end
	Mortgages, security agreements	7 years after all obligations end
Tax	IRS exemption determination and related correspondence	Permanent
	IRS Form 990s	Permanent
	Charitable Organizations Registration Statements (filed with Minnesota Attorney General)	Permanent
Human Resources	Employee personnel files	Permanent
	Retirement plan benefits (plan descriptions, plan documents)	Permanent
	Employee handbooks and faculty manuals	Permanent
	Workers compensation claims (after settlement)	7 years
	Employee orientation and training materials	7 years after use ends
	Employment applications	3 years
	IRS Form I-9 (store separate from personnel file)	Greater of 1 year after end of service, or three years
	Withholding tax statements	7 years
	Timecards, including electronic time reports	3 years
Technology	Software licenses and support agreements	7 years after all obligations end

Electronic Documents and Records

Electronic documents will be retained as if they were paper documents. Therefore, any electronic files that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

Emergency Planning

The College’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the College operating in an emergency will be duplicated or backed up.

Document Destruction

The President is responsible for the forgoing process of identifying College records, that have met the required retention period, and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.

Compliance

Failure on the part of employees to follow this policy can result in civil and criminal sanctions against the College and its employees and disciplinary action against responsible individuals. The Vice President for Finance and the Audit Committee will periodically review these procedures with legal counsel or the College’s certified public accountant to ensure that they are in compliance with new or revised regulations.

Approved by the Gustavus Adolphus College Board of Trustees: June 21, 2009.

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Federal law generally prohibits release of student academic records without prior written consent of the student. Without prior consent, however, access is permitted to employees in the same institution who have "a legitimate educational interest." This is interpreted at Gustavus Adolphus College to mean that employees may access personally identifiable information in student education records in order to fulfill their institutionally assigned professional responsibilities.

Employees seeking such access make application to the Registrar of the College, stating the need for and scope of access and the security procedures in place to protect against unauthorized internal or external use after release. Employees granted access are responsible for treating the information with confidentiality.

Approved by the Gustavus Adolphus College Board of Trustees: June 28, 1993.

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The College seeks to discourage alcohol abuse and to model the responsible use of alcohol beverages. To this end, alcoholic beverages are served at College-sponsored events only in designated locations and at designated functions.

Alcohol provided for on-campus events (and for off-campus events, whenever possible) will be purchased and supplied by the College Dining Service. Non-alcoholic beverages will generally also be available in sufficient amounts at such events, and care will be taken to ensure that applicable state, federal and local laws and regulations concerning the serving of alcohol are observed. Functions and locations at which alcoholic beverages are served must be approved at least two weeks in advance by the Director of Dining Service and the appropriate divisional vice president. Final approval by the Vice President for Finance is required for all events. Alcohol serving application forms are available from the Dining Service.

Approved by the Administrative Council: February 17, 2004.

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OVERVIEW

Travelers seeking reimbursement from the College are responsible for ensuring that travel-related expenses are for valid College business-related purposes, are in accordance with college policies and procedures and are a prudent use of college funds. All travel-related expenses should be approved by the traveler’s department chair, supervisor, or budget officer prior to making arrangements. Expenses incurred outside of this policy may not be reimbursed. It is expected that the traveler selects the most economical means when incurring travel-related expenses. Entertainment, including food and refreshment expenses associated with Gustavus-sponsored business meetings may be covered by college funds if they are actual, reasonable, and necessarily incurred in the discharge of official business-related duties.

Travel supported by grants may have more restrictive requirements than this policy. Contact the Research and Sponsored Programs Office for additional details.

IRS REQUIREMENTS

Reimbursement procedures must comply with IRS Accountable Plan rules for advances and reimbursements to be considered non-taxable income to employees (from IRS Pub 17):

• An individual must have paid or incurred expenses that are deductible while performing services for the college.
• An individual must adequately account for these expenses within a reasonable time period, and
• An individual must return any excess reimbursement or allowance within a reasonable time period.

Gustavus does not have a per diem policy. Without proper documentation, advances and reimbursements must be reported as income on an employee’s W-2 form.

DOCUMENTATION REQUIREMENTS/REIMBURSEMENT 

• Employees are expected to use their Wells Fargo purchase card for all College-related expenses. For additional detailed information on the use of the Purchase card please see the Purchase Card Policy and Procedures. 
• Reimbursement receipts are required for all transactions regardless of dollar amount. Attach all original detailed receipts, which should indicate dates, amounts, description of the expenses, and a bona fide business purpose.
• If a receipt is missing and you have done your due diligence in trying to obtain one, add a note to the transaction description stating that you cannot obtain a receipt and the reason why, and then fill out a missing receipt declaration.
• In the case of meals and entertainment expenses, the names and titles of those being entertained must be included (large groups may be described categorically). The unspecified total receipt is not sufficient. 
• If an individual is traveling longer than 7 days on a combined business/personal international trip, please contact the Finance Office in advance. There may be personal income tax implications.
• The Federal mileage reimbursement rate can be found on the Finance Office webpage (https://gustavus.edu/finance/payable.php#mileage). Only mileage above and beyond the normal commute distance from your primary residence (where you spend most of your time) will be considered reimbursable. Personal mileage reimbursement requests should not exceed the cost of an airline ticket unless there is an approved business reason for vehicle travel.
• All reimbursement requests should be submitted via an RFP within 30 days of the conclusion of the event unless prior arrangements have been made with the Finance Office. Requests after 90 days will not be accepted. 
• By submitting a reimbursement request for approval, you are attesting that the charges are correct and in compliance with College policies.
• Noncompliant requests will be returned for corrections and/or additional information as required, which could delay reimbursement. 

AIRLINE TRAVEL

• All travelers are expected to travel the most economical option at the best available fare at the time of booking.
• Seat upgrades and/or seat selection fees are at the traveler's own expense.
• Flight deviation fees are at the expense of the traveler unless dictated by the College. In this case, documentation should be included with the reimbursement request.
• Airline club memberships are at the traveler’s own expense.
• Purchase of travel/trip cancellation insurance is at the traveler's own expense.
• Reimbursement for the use of personal travel vouchers or airline loyalty programs in purchasing airline tickets used for College travel is not allowed.
• The traveler is allowed reimbursement for one bag only.

GROUND & RENTAL TRANSPORTATION

• Taxis, Uber/Lyft, shuttles, and public transportation are allowed between terminals, hotels, places of business, etc., whenever necessary. Special care should be taken when tipping with Uber/Lyft. In some cases, the tip is included with the cost of the fare.
• Due to the business relationship and preferential pricing discount the College has with Enterprise and National, they should be used for auto rentals when available. For more information regarding this process, please contact the Gustavus Motor Pool (motorpool@gustavus.edu) at 507-933-7675.
• When the traveler is on college-related business in the U.S., the driver must “decline” the optional insurance coverage. Domestic collision damage waiver and liability insurance supplement are provided through the College’s auto physical damage and auto liability insurance policies. 
• When a vehicle is rented in connection with international travel, the optional travel insurance must be purchased.

VEHICLE ACCIDENT REPORTING

In case of an accident involving a staff member traveling on college business, immediately contact 911 in emergencies as well as the Gustavus Campus Safety Office. For additional details on accident reporting, please refer to the College’s Vehicle Safety Policy.

LODGING

• It is expected that whenever possible, travelers will use reasonably priced facilities.
• An itemized listing of expenses must accompany your reimbursement request.
• Meals charged to your room account must include an original itemized receipt.
• WiFi purchase while staying at a hotel is allowed only when necessary for business related activity.
• Purchase of in-room movies or mini-bar purchases are at the traveler's expense.
• In the event that cancellations are necessary, travelers should contact the hotel immediately. Advise the hotel about early departures to avoid penalties.

MEALS/REFRESHMENTS (light snack or drink) – DURING TRAVEL

Meal/Refreshments, including gratuities, will be reimbursed at actual costs up to established maximums as listed below:

Daily maximum of $60 with a suggested breakdown as follows:

1. Breakfast $15
2. Lunch $15
3. Dinner $30
4. In cities with populations exceeding 1 million the maximum allowance is $80 (Dinner goes up $50). Exceptions to maximums may be allowed with the approval of the employee’s supervisor.

• When meals/refreshments are included in the cost of a conference, meals/refreshments taken elsewhere are not considered valid travel expenses unless there is a business or health reason.
• Allowable meals/refreshments are associated with extended workday travel, business meetings or events.
• Gratuities should be limited to 15-20%, unless automatically charged. Depending on the severity, gratuities in excess of 20% may be the responsibility of the traveler.

MEALS/REFRESHMENTS (light snack or drink) – NON-TRAVEL

Refreshment expenses for employee only meetings are allowable only when a meeting is scheduled to last two hours or longer. Please order from Gustavus Dining Services as appropriate.

Allowable Refreshment Expenses:

• Refreshments may be provided when hosting a job candidate.
• Refreshments may be provided when hosting a visiting lecturer, potential donor, or other guest on official College business.
• Refreshments may be provided at events hosted by the President, Provost, Vice Presidents, or Deans recognizing work-related achievements or milestones by employees (e.g., official retirement or service award events, etc.).
• Refreshments may be provided during official business-related meetings involving a combination of college employees and external individuals, such as a meeting with Board of Trustees members, an external task force or advisory group, or volunteers.
• College-wide events may be hosted by the President or others with prior written approval of the President, Provost, or appropriate Vice President for purposes such as opening year College events, holiday party, etc.
• The purchase of coffee and accompanying condiments (sugar, creamer, etc.) for offices if the primary consumer(s) are external individuals (i.e., prospective students, job candidates, etc.).

Allowable Meal Expenses

Meal expenses for College employees generally are a personal responsibility. However, payment or reimbursement for meals of employees may be allowed when:

• The meeting is scheduled to last four hours or longer and the primary purpose of the meeting is not the meal. In this circumstance, the meal expense requires prior written approval by the appropriate Vice President or the President.
• The meal charge is part of a conference or workshop expense;
• A search committee, or search committee representative, hosts a candidate for a position; or
• An employee hosts a visiting lecturer, potential donor, or other guest on official College business.

Non-Allowable Expenses

Certain types of expenses generally are not considered reasonable and necessary for the College, and therefore, may not be paid or reimbursed with college funds. Non-allowable expenses include payments or reimbursements for:

• Office/departmental/division parties or employee/student worker meals and entertainment.
• Holiday and/or end of year celebrations for employees and/or student workers.

ALCOHOL EXPENSES

Alcohol consumption is strictly prohibited before the end of your workday. The College will reimburse for alcohol as a beverage with a meal if the meal includes at least one individual who is not a Gustavus Adolphus College employee. In addition to the IRS reimbursement requirements listed above, the following conditions must also be met:

• Employees must use prudence in these circumstances and may not purchase an unreasonable amount of alcohol (one drink per person is typically considered reasonable) nor at an unreasonable cost as compared to the overall cost of the meal. Generally, the cost for a single drink should be under $10, not including tip.
• Alcoholic beverages consumed by travelers between or after mealtimes are not reimbursable, except when they qualify as necessary entertainment for donor solicitation. Receipts submitted to substantiate such purchases should note the name of the donor and the nature of the meeting.
• Students may not participate in the purchase and/or consumption of alcohol under any circumstances.
• Alcoholic beverages may not be charged to federally funded grants or contracts, either directly or indirectly.

There may be other occasions when it is necessary for alcohol to be reimbursed. These instances will be rare and must be pre-authorized by the President, Provost, or appropriate Vice President. Please include the approval with the reimbursement request.

Employees are reminded that use of college money to purchase alcohol can expose the College to additional liability should injuries occur as the result of alcohol consumption. See the Alcohol Serving Policy for additional information: 

OTHER ALLOWABLE TRAVEL EXPENSES

Reasonable expenses incurred by the employee may be reimbursed and may include:

• Laundry and Dry Cleaning: only allowed on extended trips of more than seven days, when it is not practical to bring enough clothing for the whole trip.
• Telephone: Telephone calls for business purposes are allowed. Personal phone calls are only allowed on extended trips.

NON-REIMBURSABLE TRAVEL EXPENSES

• Costs for meals, travel or lodging of spouses, dependents and/or other guests
• Valet parking service
• Health spa fees
• Theft or loss of personal belongings
• Personal entertainment or excursions
• Toiletries, medicine, magazines, etc.
• Traffic & toll violations/fines
• Personal property insurance premiums
  

APPROVAL/AUTHORIZATIONS

Listed below are the approvers’ responsibilities:

• Review documentation for completeness in support of the charges.
• Ensure the charges are in accordance with College and IRS policies.
• Resolve missing or inadequate documentation prior to submission to Finance.
• Obtain additional approval if charges are going to another department.
• Include written approval by the appropriate Vice President or the President when required to allow exceptions to this policy. 

EXCEPTION PROCESS

Written approval by the appropriate Vice President or the President is required to allow exceptions to this policy. Please include the approval with the reimbursement request. 

EQUIPMENT LOSS PREVENTION & SECURITY WHILE TRAVELING

Gustavus employees using personal or College owned laptops or related devices while traveling should only use secured Wi-Fi connections while accessing Gustavus and related cloud-based systems that may contain sensitive information. A secure network requires a user to agree to the legal terms, register an account, or type in a password before connecting to the network. 

Gustavus can provide a secure Mi-Fi (Hotspot) device or other secure remote access solutions for use during travel if necessary. If you believe that your laptop has been compromised, it is YOUR responsibility to immediately contact Campus Safety (507-933-8888).

Employees should never leave their laptop or related devices unattended while traveling. Equipment should be locked in a secure location (ex. hotel room, safe, locked office space, etc.) while away and/or outside of normal business hours. 

If a Gustavus phone, laptop or other device is stolen, it is YOUR responsibility to immediately contact Campus Safety (507-933-8888). 

Approved by the President's Cabinet: October 14, 2008. Revised July 20, 2021, October 11, 2022, and by the Executive Leadership Team (XLT) September 3, 2024.

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Introduction

A basic component of the Gustavus Adolphus College’s risk management program is a vehicle safety policy that establishes the safety guidelines for its authorized drivers when driving for Gustavus business. The administration of the college’s vehicle policy requires the consistent implementation of strong policies and procedures to ensure that drivers and departments know their responsibilities and carry them out. The following guidelines have been established to help control the operation of Gustavus owned, rented or personal vehicles driven for college business purposes. Gustavus owned vehicles include: all motor pool vehicles, large vans, trucks, minivans and cars. 

Driver Qualification

To help ensure only well-qualified drivers, Gustavus will adhere to the following procedures:

1. Driver’s License
   1. All Gustavus faculty, staff and students whose duties may require them to operate a Gustavus vehicle will have a valid driver’s license appropriate for the type of vehicle they will be driving.
   2. The employee will provide a copy of the driver’s license during the hiring process or it will be obtained at the time the Gustavus owned vehicle is requested.
   3. Driver’s license validity will be checked periodically or upon request thereafter. Gustavus will maintain a copy of the license in the employee’s personnel file and Gustavus will maintain these files. Driver qualification criteria can be found at the EHES Risk Management Website under Safety & Health Policies titled Vehicle Driver Qualification.
2. Assigned Vehicles
   
   Some vehicles may be assigned to departments to complete job duties, such as Facilities, Campus Safety, Athletics, etc. The employees should operate and maintain these vehicles as though they were their own.
   
   Gustavus vehicles may be operated by faculty, staff or students, depending on the need. Control of these vehicles will be maintained through Gustavus Adolphus College.
   1. When a department wishes to use a vehicle for a specific purpose, the requestor will complete a Vehicle Use Request form and submit it to Gustavus Adolphus College Motor Pool as soon as possible. If the requesting department plans to provide the driver, the names of all drivers should be provided with the Vehicle Use Request form and the drivers should be verified against the Gustavus Adolphus College’s list of eligible drivers.
   2. Vehicles will not be loaned, leased or rented to others.

Training

1. Driver Training
   
   In order to understand the responsibilities and techniques for driving safely, all drivers must be able to demonstrate their skills in the operation of their assigned college-owned vehicles. If they are not able to demonstrate their driving skills, they will be trained in the appropriate techniques. For example, if a driver needs to be able to drive a 10-passenger van or a vehicle with an attached trailer, but does not have experience in such a vehicle, he/she must be trained until he/she can demonstrate mastery of that vehicle’s operation. This training will be provided by Gustavus Adolphus College, which may include classroom, individual instruction and audio-visual methods, or online courses, as appropriate.
   1. New Gustavus Adolphus College drivers are authorized after successful completion of an online safety program at time of hire or initial authorization and refreshed periodically as required by Gustavus Adolphus College.
   2. Drivers will be responsible for taking new courses as they become available.

Pre-Post Trip Safety

1. Trip Forms
   1. The driver will complete and sign a Pre-/Post-Trip Vehicle Inspection form indicating that they have inspected the vehicle. The driver will always keep a copy with him/her while operating the vehicle and will complete the post-trip section upon return to campus.
   2. Headlights, taillights, wipers and windows must be operational and clean before operating the vehicle.
   3. The driver should also verify that a copy of the accident report form and current insurance card are available in the glovebox of vehicle.
   4. Upon return from the trip, the driver will return the completed copy of the Pre-/Post-Trip Vehicle Inspection form when turning in the vehicle keys. The driver will complete a brief vehicle inspection using the Pre-/Post-Trip Vehicle Inspection form and document any mechanical problems with the vehicle, service required, new damage, the amount of gas added, the number of miles driven and any service that may have been provided to the vehicle. Gustavus Adolphus College will return the signed copy of the Pre-/Post-Trip Vehicle Inspection form to the driver and retain the original copy along with the Vehicle Use Request form in the vehicle file.
2. Maintenance
   
   In order for Gustavus vehicles to have a long and useful life, they must be maintained regularly. Accordingly, the college has established a Preventive Maintenance Program to include all Gustavus vehicles and equipment and should be performed in compliance with manufacturer specifications.
   1. Gustavus Adolphus College will maintain a list of all College vehicles. The list will include the manufacturer’s recommended intervals for preventive maintenance services, as well as the dates/times and types of services that have been performed on the vehicles.
   2. Facilities will review the list to determine which vehicles are due for maintenance services. The College will then designate a person to either perform that service or take the vehicle to the designated service provider.
   3. For vehicles assigned to one person or department for their exclusive use, such as Campus Safety or Dining Service, Facilities will notify that person or department when the service is due. That user will then be responsible for having the maintenance services completed and documented with Gustavus.
   4. If a vehicle has operational problems while off-campus, the driver will notify Facilities during normal office hours and Campus Safety after hours. If the vehicle cannot be operated safely, the Facilities department will make the necessary arrangements to bring the driver back to campus and have the vehicle transported to a designated service location.

Trip Safety

1. Seat Belts
   Seat belts are one of the most important pieces of safety equipment installed on a motor vehicle. It should be noted that the use of seat belts is entirely under the control of the driver. All drivers should follow the procedures listed below as a condition of driving any vehicle for Gustavus business purposes:
   1. When going on a trip, including on campus and even a short trip across town, ensure that there is a seat belt for every passenger. If not, limit the number of passengers to the number of seat belts available.
   2. Before shifting from “Park”, the driver must secure his/her seat and shoulder belt and verify that all passengers are appropriately secured by their seat and shoulder belt.
2. Drug and Alcohol Use
   No driver authorized by Gustavus should be under the influence of any drug or alcohol while operating a vehicle while on college business. Please see the Gustavus Drug and Alcohol policy.
   
   
3. Smoking Prohibited
   All campus vehicles must remain smoke-free. Use of tobacco or vape-related products in campus vehicles is prohibited. Please see the Smoking and Tobacco policy.
   
   
4. Cell Phones
   Cell phone and other electronic device use in any vehicle used for college business while it is in motion may only be used to make calls through the assistance of Bluetooth or other hands-free options. Headphones that reduce hearing should not be used. For navigation devices, program the destination before starting the vehicle, pull off the road to make changes and rely on the voice directions or the front seat passenger to guide you.
   
   
5. Vehicle Accidents/Incidents
   In the event a vehicle accident:

• • Protect vehicle occupants from hazards and the vehicle from further damage.
  • Call police or Campus Safety if on campus. Campus Safety may be reached 24 hours a day at: (507) 933-8888.
  • Request medical assistance, if required.
  • Be sure to get the name and address of each driver, passenger, and witness, and insurance company and policy number for each vehicle involved.
  • Do not assume responsibility for accident.
    
    Only discuss the accident with police officers or Travelers Insurance representatives. The Accident and Incident Form should be in each vehicle in case there is a need to complete it. Please fill it out and send a copy to Risk Management within 24 hours of an incident.
    
    Primary insurance will follow ownership of the vehicle. Therefore, when an employee is driving a personal vehicle for college business, personal insurance information should be provided in the event of an accident or incident. When renting a vehicle for college business, additional insurance should only be purchased if travelling internationally. Otherwise, the Gustavus insurance policy will be primary when an accident or incident occurs. 

More information regarding Vehicle Safety programs can be found on the Environmental Health, Safety and Risk Management website. 

Approved by the President's Cabinet: November 9, 2021.

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