8. Employee Responsibility

801 Employee Conduct and Work Rules

Professional Conduct

The Washington Research Library Consortium expects its employees to behave in a professional, business-like manner at work, on WRLC premises, and whenever representing the WRLC.

The WRLC’s standards of conduct include, but are not limited to the following:

  • Employees should report to work on time.
  • Employees are expected to dress appropriately for their position whenever working or representing the WRLC. Employees who ride or operate heavy machinery must dress according to all OSHA guidelines.
  • Unauthorized use of WRLC resources, such as telephones, copiers, computers, fax machines, postage, courier services, office supplies, and other business equipment and supplies is prohibited. The WRLC recognizes that its employees may occasionally need to use WRLC-provided electronic resources for personal matters and does not wish to prohibit such use altogether. The overriding principle that should govern personal use of these resources is that reasonable and incidental unofficial use of WRLC electronic resources is authorized only so long as (i) the WRLC incurs no additional cost from that use, other than the minimal cost incurred from ordinary wear and tear and the use of minimal amounts of ink, toner, or paper; and (ii) the use does not inappropriately interfere with official business.
  • Theft, unauthorized removal, negligence or misuse of WRLC property or property of WRLC colleagues is prohibited.
  • During the course of their work hours, WRLC employees should only conduct duties related to their jobs at the WRLC. Employees should not conduct personal business during work hours or use WRLC resources for personal business.
  • Unauthorized use, possession, or storage of firearms, dangerous weapons, explosives or lethal materials on WRLC premises or at WRLC-sponsored activities is prohibited, whether or not a federal or local license to possess the weapon or material has been issued.
  • Employees are expected to inform their supervisor of any visitors to the WRLC prior to the visitors’ arrival.
  • Fighting, threatening violence, insubordination or other disrespectful conduct is not permitted.

Conflicts of Interest

All employees must avoid actions that are or could be perceived as a conflict of interest between their personal, financial, or professional interests and the interests of the WRLC. A conflict of interest may occur if an employee or a member of the employee’s immediate family or household:

  • has an existing or potential interest, financial or non-financial, that may impair or appear to impair the individual’s independent judgment when performing WRLC responsibilities; or
  • receives or may receive a material, financial, or other benefit from knowledge of confidential or proprietary information regarding the WRLC.

Employees who believe they are involved in a matter or activity in which a conflict of interest may exist should promptly and fully discuss the situation with their Director. The individual must refrain from further participation in the matter until the question is resolved and follow any directions given by the WRLC concerning the matter.

Felony or Misdemeanor Convictions

If an employee is convicted of a felony or misdemeanor while employed by the WRLC, the employee must notify his or her Director immediately following the conviction. The WRLC may terminate the employee as a result of the conviction or for failure to provide notice of the conviction.

Subpoenas

Subpoenas and any other request or demand for the release of information for a legal proceeding must be referred to the WRLC’s Executive Director. No information is to be released without the approval of the Executive Director.

802 Personnel Data Changes

To ensure accurate and current information on each employee and their dependents it is essential that employees promptly notify the Director of Finance and Administration of any changes related to your personnel information. Examples include:

  • Mailing address
  • Telephone number(s)
  • Dependent’s names
  • Individuals to contact in the event of an emergency

803 Drug and Alcohol Use

It is the WRLC's desire to provide a drug-free, healthy, and safe workplace. To promote this goal, employees are required to report to work in appropriate mental and physical condition to perform their jobs in a satisfactory manner.

While on the WRLC premises and while conducting business-related activities off WRLC premises, no employee may use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs. The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's ability to perform the essential functions of the job effectively and in a safe manner that does not endanger other individuals in the workplace.

Under the Drug-Free Workplace Act, an employee who performs work for a government contract or grant must notify WRLC of a criminal conviction for drug-related activity occurring in the workplace. The report must be made within five days of the conviction.

Violations of this policy may lead to disciplinary action, up to and including immediate termination of employment, and/or required participation in a substance abuse rehabilitation or treatment program. Such violations may also have legal consequences.

Employees with questions on this policy or issues related to drug or alcohol use in the workplace should raise their concerns with their supervisor or the Director of Finance and Administration without fear of reprisal.

804 Attendance and Punctuality

Employees should report to work on time and sufficiently prepared for the workday. In those infrequent instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify their supervisor as soon as possible in advance of the anticipated tardiness or absence.

Frequent or unscheduled absences and repeated lateness may result in disciplinary action. Employees who are absent from work for three or more consecutive days without calling to report the absence may be terminated from employment based on job abandonment.

805  Use of Equipment

Equipment is made available to WRLC employees so that we can accomplish our mission of providing proactive and responsive, innovative, cost-effective access to shared information resources, services and expertise. When using these assets, employees are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards, and guidelines. If any equipment, machines, or tools appear to be damaged, defective, or in need of repair, please inform your supervisor promptly to prevent deterioration of the equipment and possible injury to employees or others.

Employees will be expected to reimburse the WRLC for any expenses resulting from personal use of WRLC equipment and supplies (including long-distance or mobile telephone service, printing and copying, etc.) that go beyond incidental use.

The WRLC allows the use of company postage, and shipping and delivery services on a full reimbursement basis. All postage used for personal mail should be recorded on the log form located in the supply room. When completing UPS, Postal or FedEx air bills, indicate "personal" in the reference area. The accounting staff will periodically prepare an invoice and distribute to each employee. Payment is due upon receipt.

807 Business Ethics and Conduct

The WRLC will comply with all applicable laws and regulations and expects its directors, managers, supervisors, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, violent, dishonest, or unethical conduct.

If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed with your immediate supervisor, department director, Director of Finance and Administration or the Executive Director.  

If any employee reasonably believes that some policy, practice, or activity of The Washington Research Library Consortium (“WRLC”) is illegal or dishonest, a written complaint must be filed by that employee with the person(s) listed in the Whistleblower policy. An employee filing the written complaint is known as a “whistleblower” and is protected from retaliation. See the Whistleblower Policy.

Compliance with this policy of business ethics and conduct is the responsibility of every WRLC employee.

808 Confidentiality of information

Certain information maintained by the WRLC is confidential and subject to specific state and federal laws and regulations. All confidential information must be protected against unauthorized access and disclosure. Unauthorized access and/or disclosure of confidential information by WRLC employees is prohibited and may result in disciplinary action and legal penalties.

Safeguarding patron data

Various applications maintained by the WRLC on behalf of the partner universities contain personal data (e.g., ID numbers, addresses, phone numbers, materials requested or borrowed, electronic databases used, websites visited). Patron information must be held as CONFIDENTIAL.

To safeguard patron information and to comply with federal law (notably the Family Educational Rights and Privacy Act (FERPA)), no WRLC staff member may disclose any information concerning a patron (student, faculty or staff of our partner universities or any other user of WRLC resources) except with the approval and under the direction of WRLC’s Executive Director.

Patron information may be disclosed only:

  • When requested by authorized staff of participating WRLC universities performing their essential job functions
  • Upon written consent of the patron
  • Pursuant to court order or where otherwise required by law.

In addition, WRLC staff may not access or use personal patron data for any purpose unrelated to providing contracted services to the participating universities. WRLC staff will take all reasonable steps to ensure that confidential patron information in electronic and paper records is not made visible to unauthorized persons. This includes the use of artificial intelligence and other large data analysis models provided by vendors or other entities outside of the 9 consortial partners. 

Violation of this policy will be grounds for disciplinary action, up to and including immediate termination.

Responding to requests for patron data from external organizations

The WRLC may receive requests for patron information from external organizations including departments of the participating WRLC universities, vendors, other private parties, or law enforcement agencies. In every case, regardless of the source or nature of the request, the WRLC staff member who receives the request must contact and get authorization to proceed from the Executive Director . Refer to the appropriate section below if you receive a request for patron information.

Request from an office at a partner university other than the library

The WRLC director notified about the request for patron information will contact the Library Director of the patron’s home university. WRLC will release the requested information only to the Library Director or their designee.  

Law Enforcement Official

If a Law Enforcement Official informally requests patron information, DO NOT PROVIDE IT. Ask to see official identification, and then contact the Executive Director or the Director, Finance and Administration. If the agent or officer does not have a court order, the WRLC director will inform him/her that patron records cannot be provided without a proper court order in good form. Without a court order, neither the FBI nor local law enforcement has authority to compel cooperation with an investigation or require answers to questions, other than the name and address of the person speaking to the agent or officer.

If a Law Enforcement Official presents a subpoena, a court order, or other legal document, ask to see official identification and contact the Executive Director or the Director, Finance and Administration. The WRLC director will immediately refer the court order to legal counsel for review. There are two kinds of court orders which might be presented:

  • a subpoena, which allows WRLC a period of time to respond to and contest the court’s order
  • a search warrant, which can be executed immediately. An agent or officer serving a search warrant can begin the search as soon as the warrant is served. Staff should “step aside” but are entitled to consult with legal counsel and to ask that legal counsel be present during the search.

If the court order is a search warrant issued under the Foreign Intelligence Surveillance Act (FISA) (USA Patriot Act amendment), special conditions apply. A search warrant issued by a FISA court contains a “gag order” which means that no person or institution served with the warrant can disclose that the warrant has been served or that records have been produced pursuant to the warrant. WRLC staff must comply with this order. No information can be disclosed to any other party, including the patron whose records are the subject of the search warrant. WRLC staff should notify the WRLC’s designated administrator(s) that an officer or agent has presented a search warrant, but should not indicate the nature of the search warrant. The gag order does not change the WRLC’s right to legal representation during the search. The WRLC can still seek legal advice concerning the warrant and request that legal counsel be present during the actual search and execution of the warrant.

809 Whistleblower Policy

If any employee reasonably believes that some policy, practice, or activity of The Washington Research Library Consortium (“WRLC”) is illegal or dishonest, a written complaint must be filed by that employee with the person(s) identified below under this policy. It is the intent of the “WRLC” to adhere to all laws and regulations that apply to the organization and the underlying purpose of this policy is to support the organization’s goal of legal compliance. The support of all employees is necessary to achieving this goal. An employee filing the written complaint is known as a “whistleblower” and is protected from retaliation only if the employee brings the alleged unlawful activity, policy, or practice to the attention of the “WRLC” in good faith and provides the “WRLC” with a reasonable opportunity to investigate and correct the alleged unlawful activity. The protection described below is only available to employees that comply with this requirement.

The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Such activity may include another employee or outside persons or firms doing business with WRLC.  Examples of illegal or dishonest activities are violations of federal, state or local laws, fraudulent financial reporting and other inappropriate actions.

Employee Reporting Process

If an employee has knowledge of or concern of illegal or dishonest activity, the employee may communicate with any of the following:

  • His/her immediate supervisor
  • Director of Finance and Administration
  • Executive Director

Any violation involving a member of senior staff should be reported to the Chair of the Board of Directors.

Communications may be verbal, but a written communication would be preferred.  No particular format is necessary.  Communications should include all information necessary to properly and completely evaluate the complaint or charge.  This includes material evidence, names of persons able to corroborate the accusation and how to contact the complainant to assure anonymity, if anonymity is desired.  (Note: Anonymity may hinder the ability to investigate the matter in a timely and effective manner).

Role of the Executive Director

All reports of illegal and dishonest activities will be promptly submitted to the Executive Director, who is responsible for overseeing the investigation and coordinating corrective actions.  The Executive Director will determine the level of investigation the complaint warrants and who the appropriate party is to perform the investigation. The Executive Director is responsible for determining if the facts support or do not support the complaint. In either case, the Executive Director will notify the employee who made the complaint of the decision and the reason thereof.

The Executive Director in his/her discretion may report to the WRLC’s general counsel complaints received under this policy, their status and resolution. The Executive Director is required to report quarterly to the Audit Committee a summary of complaints, if any are received under this policy, their status, resolution and the WRLC’s compliance with this policy.

For violations involving a member of senior staff, the Chair of the Board of Directors will fill the role of the Executive Director and perform the responsibilities identified in the preceding paragraphs.

Employee Responsibility

An employee who reports a complaint or charge must exercise sound judgment and act without malice to avoid baseless allegations or frivolous complaints.

Employee Protection

Whistleblower protections are provided in two important areas – confidentiality and against adverse action in the form of retaliation.

Insofar as is reasonably possible, the confidentiality of the whistleblower will be maintained.  However, at the discretion of the Executive Director or the Chair of the Board of Directors, after consultation with general counsel, the whistleblower’s identity may have to be disclosed to conduct a thorough investigation or to comply with the law.

The WRLC will not take adverse action against a whistleblower solely as a consequence of his/her acting as a whistleblower. This includes, but is not limited to, protection from employment action such as termination, compensation decreases, poor work assignments and threats of physical harm. Any whistleblower that believes he/she is being retaliated against should immediately contact the Executive Director or the Chair of the Board of Directors, if appropriate.

Any employee, however, who knowingly files a false or materially misleading report of wrongdoing, is subject to discipline.

Questions

Employees with questions regarding this policy should contact the Director of Finance and Administration.

810 Sexual and Other Unlawful Harassment

It is the policy of the WRLC to prohibit harassment on the basis of race, color, religion, sex, national origin, age, marital status, personal appearance, sexual orientation, gender identity or expression, familial status, family responsibilities, matriculation, political affiliation, genetic information, disability, source of income, sealed eviction record, status as a victim of an intrafamily offense, place of residence or business, status as a victim or family member of a victim of domestic violence, a sexual offense, or stalking, homeless status, or any other characteristic protected by law (collectively “protected classifications”).. Harassment is strictly prohibited whether taking place in person at a physical work location or event or carried out through digital communication platforms like email, chat, video calls, or social media.

Sexual Harassment

For the purposes of this policy, sexual harassment is defined as any unwelcome sexual advance, request for sexual favors or other verbal or physical conduct of a sexual nature when:

  • submission to such conduct is made explicitly or implicitly a term or condition of an individual's employment or advancement; or
  • submission to or rejection of such conduct is used as a basis for making an employment decision affecting an individual; or
  • such conduct has the purpose or effect of interfering with an individual's performance, or of creating an intimidating, hostile, or offensive environment.
  • sexual harassment may occur between persons of the same or opposite gender.

Although sexual harassment often occurs when one person takes advantage of a position of authority over another, the WRLC recognizes that sexual harassment may also occur between people of equivalent status. Regardless of the form it may take, the WRLC will not tolerate conduct of a sexual nature that creates an unacceptable working environment.

Harassment Other Than Sexual Harassment

Harassment, other than sexual harassment, is verbal or physical conduct that denigrates or shows hostility or aversion to an individual because of a protected classification, when such conduct has the purpose or effect of:

  • unreasonably interfering with an individual’s performance;
  • creating an intimidating, hostile, or offensive environment;
  • or otherwise adversely affecting an individual’s employment opportunities.

Harassment may include, but is not limited to: verbal abuse or ridicule, including slurs, epithets, and stereotyping; offensive jokes and comments; threatening, intimidating, or hostile acts, and displaying or distributing offensive materials, writings, graffiti, or pictures.

National Origin and Accent Harassment

The Equal Employment Opportunity Commission (EEOC) has taken the position that harassment of employees on the basis of their national origin or their accent or manner of speaking is a violation of Title VII of the Civil Rights Act of 1964 as amended. Under EEOC guidelines, ethnic slurs and other verbal or physical conduct relating to an employee’s national origin, surname, skin color or accent would constitute unlawful harassment when such conduct:

  • has the purpose or effect of creating an intimidating, hostile or offensive working environment,
  • has the purpose or effect of unreasonably interfering with the employee’s work performance,
  • or has the purpose or effect of adversely affecting his or her employment opportunities.

Procedure for Complaints

Any employee of the WRLC who believes that conduct that violates this policy has occurred, or who has questions concerning this policy, is encouraged to contact the Director of Finance and Administration.

In addition, the WRLC recognizes that supervisors bear a particularly important responsibility to deter harassment. Supervisors who learn of conduct that may violate this policy should immediately contact the Director of Finance and Administration, and, as appropriate, inform their own supervisors.

In accordance with the guidelines of the EEOC, all complaints will be investigated impartially, and appropriate corrective action will be taken, including discipline for inappropriate conduct. Complaints will be handled confidentially, except as necessary for investigation and resolution.

This policy prohibits retaliation, harassment, or other adverse action against an individual for making a complaint, assisting in an investigation, opposing harassment or otherwise exercising rights protected by law. It further prohibits taking any adverse employment related action against an individual based on an unsubstantiated allegation or rumor of harassment.

812 Outside Employment and Consulting

Employees may engage in consulting or outside employment activities with the express written approval of their supervisor and the Executive Director, and as long as the activities do not interfere with their WRLC responsibilities and duties, or result in a potential conflict of interest, or unfair competitive situation for the WRLC.

If the WRLC determines that an employee's outside work interferes with performance or the ability to meet the requirements of the WRLC, the employee may be asked to terminate the outside employment if he or she wishes to remain with the WRLC.

Employees must not use WRLC resources to support such outside employment or consulting.


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