MGIC - Financial Conduct and Responsibility

Financial Conduct and Responsibility

Purpose

The purpose of this policy is to describe the expected conduct of personnel employed by the University of Maryland, Baltimore (UMB), the Maryland Global Initiatives Corporation (MGIC) and the constituent institutions of the University System of Maryland that do business with MGIC (hereafter referred for purposes of MGIC policies only as UMB Affiliate Entities), who are entrusted with responsibility for MGIC financial management and who utilize MGIC finance services to facilitate international work.

Background

All users, administrators, and governing oversight authorities of MGIC are called upon to develop and maintain the highest standards of integrity and professionalism in conducting MGIC business.

MGIC has zero tolerance for violations of the MGIC Ethics and Conduct Policy – an overarching MGIC corporate policy to which Financial Conduct and Responsibility is closely related – and will not tolerate fraud and other fiscal irregularities, undisclosed conflicts of interest, and other illegal and unethical behavior and misconduct. Anyone found to be engaging in any type of improper, unethical, or illegal behavior, violating these policies, or retaliating against a whistleblower, shall be subject to disciplinary action, up to and including termination of employment, as appropriate. Violations that are criminal offenses may be referred for legal prosecution.

All UMB personnel and affiliates, including MGIC employees, are required to abide by the MGIC Conflict of Interest prohibitions and Standards of Conduct incorporated in MGIC policies, in all their dealings with vendors, service providers, collaborating partners, and other parties engaged through MGIC on behalf of UMB or an Affiliate Entity. No MGIC information, position, or property may be used for improper personal gain or benefit, and no MGIC, UMB, or other affiliate personnel may compete with MGIC directly or indirectly.

Specifically, as relates to financial management, UMB and affiliate personnel implementing MGIC financial activities must abide by the following policies, and must consistently comply with the Code of Ethics and Conduct of their respective employer. 

Policy Statement

1. No monies or assets will be used directly or indirectly for unlawful or improper purposes, or for the personal benefit of any personnel.
2. Financial data will be accurate, complete, timely, and prepared in accordance with MGIC policy and applicable financial reporting laws of the country in which financial transactions are made.
3. No unauthorized, undisclosed, or unrecorded accounts or funds will be established or maintained for any purpose.
4. No contributions will be made directly or indirectly for any political purposes.
5. No payments or contracts will be solicited or received, directly or indirectly, by any personnel or their family member from an MGIC vendor or partner organization. Family members include but are not limited to: spouses, domestic partners, parents, siblings, biological and adopted children, grandparents, grandchildren, aunts and uncles and their children (first cousins), nieces and nephews, parents-in-law, sons- and daughters-in-law, and brothers- and sisters-in-law.
6. No payments will be made directly or indirectly to any family member of MGIC employees or UMB or affiliate personnel who are involved in any way whatsoever in the procurement, payment, or professional benefit of the goods, services or activity received by the payee.
7. UMB and affiliate personnel, including MGIC employees, whose family member(s) may be in a position to offer goods, services, or activities to UMB/Affiliate or MGIC in exchange for payment, must complete a Conflict of Interest disclosure and must recuse themselves from participation in the selection, approval, or receipt of any work in which their family member has an interest.
8. No payments, gratuities, or gifts will be made, directly or indirectly, to any official or employee of any government or government agency – with the exception of authorized payments related to MGIC-purchased goods and services, training and conference events, honoraria and stipends for UMB/Affiliate-authorized purposes, and certain authorized business meals.
9. Any potential or existing conflict of interest will be reported through the Ethics Hotline and/or through submission of a Conflict of Interest Disclosure.
10. All payments to agents, brokers, and vendors for the purchase of goods and services will be appropriate to the services performed and will be supported by binding contractual instruments or agreements, properly authorized letters of invitation or offers of compensation, or other equivalent evidence of financial commitment as described and required in specific MGIC finance and procurement policies.
11. Furthermore, regarding bank accounts, loans, and advances:
    • Only the MGIC Board of Directors can authorize the establishment of bank accounts in the name of MGIC.
    • No UMB or affiliate personnel or MGIC employee may borrow money from a lending institution or individual in MGIC’s name.
    • Personal loans or salary advances are prohibited except in highly unusual circumstances and with written approval from the Requesting Unit and MGIC President.
12. Personnel are required to report any reasonably suspected or confirmed violations of these standards through the Ethics Hotline.

Scope

This policy applies to all UMB personnel and affiliates, including MGIC employees, who use or administer business operations and services through MGIC.

Responsibilities

1. International Operations - International HR Manager: Collect and maintain Conflict of Interest Disclosure forms from all MGIC employees.
2. Assistant Vice President - IO in their capacity as MGIC Vice President – Policy & Administration: Maintain MGIC policies and oversee IO division compliance.
3. MGIC President: Approve or deny personal loans or salary advances to MGIC employees, together with approval of Requesting Unit.
4. MGIC Board of Directors: Authorize the establishment of bank accounts in the name of MGIC.
5. All UMB personnel and affiliates, including MGIC personnel: Comply fully with this policy. Complete and submit MGIC Conflict of Interest Disclosure forms as applicable. Report any reasonably suspected or confirmed violations of this policy through the Ethics Hotline.

Procedures

See MGIC Standard Operating Procedures.

Documentation Requirements

• Ethics Hotline
• Conflict of Interest Disclosure

References

• MGIC Policy on Ethics and Conduct