1007: Code of Conduct for the Officers and Senior Administrators of Georgetown University


This Code sets standards for the professional conduct of the officers and senior administrators of Georgetown University.  By “officers and senior administrators,” this code means the members of the President’s Cabinet and any other senior administrator designated by the President for inclusion hereunder.  The obligations described in this Code apply in addition to those imposed on officers and senior administrators by other policies.


Institutions of higher education are entrusted by society with significant resources and concomitant responsibilities for creating, disseminating, and preserving knowledge through the processes of scholarly teaching, research, and service.  The institution’s officers and senior administrators must play a key role in assuring that high standards of ethical conduct, objectivity, and professional competence guide the institutional decision-making process at all times.


Statement of Institutional Standards

All officers and senior administrators of Georgetown University are expected to support the mission of the University as a Catholic, Jesuit institution of higher education, to remain knowledgeable about the University’s structure, goals, policies, and educational offerings, and to carry out their duties in a manner that is consistent with the requirements of applicable law and in accordance with the Charter and bylaws and the University’s Code of Ethical Conduct.  Officers and senior administrators should set an example of excellence for others at the University in the ways that they meet the requirements of University policies and avoid even the appearance of impropriety.  In addition, all officers and senior administrators understand and are expected to adhere to the following standards in their capacities as administrative leaders.

Adherence to Code of Ethical Conduct

The Georgetown University Code of Ethical Conduct articulates the basic standards and expectations that guide all Georgetown employees in their work, interactions, and daily decision-making.  Officers and Senior Administrators at the University have a particular responsibility to uphold the shared values and commitments set forth in the Code and to model them for others in the University community.  To that end, the University requires that Officers and Senior Administrators read and understand the Code, strive to uphold the principles and values set forth in the Code and use their best efforts to see that those they supervise do so as well, and complete an annual certification with the Office of Compliance and Ethics.

Standards Relating to Officers’ and Senior Administrators’ Fiduciary Obligations 

Officers and senior administrators have an obligation to act in good faith and in the University’s interests without receiving improper personal benefits and in a way that is not unduly motivated by self-interest.

Officers and senior administrators shall:

  • Understand their fiduciary obligations as members of University administration.  Officers and senior administrators understand that they are under an enforceable legal duty to the University to direct and manage its affairs knowledgeably and prudently.
  • Read and be familiar with the University’s Congressional charter and Bylaws.
  • Avoid even the appearance of a conflict of interest that might cause injury or embarrassment to the University, and comply with the University’s Financial Conflicts of Interest Policy.

Standards Relating to Confidential or Proprietary Information

In addition to the obligations that are imposed upon them under other applicable University, campus, and departmental policies, officers and senior administrators shall:

  • Honor their obligation to preserve the confidentiality of sensitive or proprietary information concerning the management and financial affairs of the University.
  • Refrain from using sensitive or proprietary information to which they have access by virtue of their University positions for personal gain or in any other inappropriate manner.
  • Maintain the confidentiality of the deliberations of the Board, Cabinet, and other administrative bodies when those bodies meet in executive session.

Standards Relating to Avoidance of Conflicts of Interest

The University’s officers and senior administrators are men and women who inevitably are involved in the affairs of other institutions and organizations.  Although many actual or apparent conflicts of interest arising from such involvement are and will be deemed to be inconsequential, each officer and senior administrator must conduct his or her University-related activities in a manner that is objective, independent and impartial and that assigns first priority to the needs and goals of the University.  Officers and senior administrators must recognize that even the appearance of an undue influence or conflict of interest with respect to their actions can be harmful to the University and to their effectiveness and must make the University aware of situations in which their objectivity could be questioned.

Officers and senior administrators, like other University employees, are subject to the requirements and disclosure obligations of the University’s Financial Conflicts of Interest Policy and must read that policy and pay particular attention to meeting its disclosure and other requirements.  

In addition to the requirements of the Financial Conflicts of Interest Policy, officers and senior administrators have the following obligations:

  • Unless the circumstances have been previously disclosed and the officer or senior administrator’s participation has been approved by the University: Any officer or senior administrator who has or may have an actual, potential or apparent conflict of interest with respect to a subject shall not participate or use any personal influence in the discussion of the subject or make any recommendations regarding the subject.  An officer or senior administrator shall not vote on or participate in the consideration of any matter with respect to which an actual or potential conflict of interest exists, and shall not be counted in determining the quorum for action on such matter.  The minutes of the meeting shall reflect that the officer or senior administrator did not participate in the discussion and abstained from voting.
  • Whenever an officer or senior administrator has a question about whether a personal or familial outside interest, relationship or activity that has not been disclosed pursuant to the Financial Conflicts of Interest Policy could reasonably be perceived as undermining their objectivity, they shall seek immediate advice from the General Counsel or the Secretary of the University.
  • If any officer or senior administrator perceives the existence of an actual, potential or apparent conflict of interest involving another officer or senior administrator, he or she shall immediately notify the General Counsel.

The Secretary of the University shall hold information relating to conflicts of interest that are disclosed pursuant to this Code in confidence except as required by law or as may be determined by the President to be in the best interests of the University.  In some cases, it may be determined that after full disclosure to those concerned, the University’s interests are best served by participation by the individual despite an apparent conflict of interest.  Under such circumstances, the President may authorize such participation. 

Implementation and Certification 

On an annual basis, each officer and senior administrator will be asked to fill out and sign a Certificate of Compliance attesting to the fact that he or she has read this Code of Conduct for Officers and Senior Administrators and is in compliance with it.  The completed certificates will be returned to the Secretary of the University for filing and safekeeping.

This policy is to be interpreted and applied in a manner that will best serve the interests of the University.  Any officer or senior administrator who desires assistance in interpreting and construing the terms of this policy may seek advice from the General Counsel or the Secretary of the University.

All candidates for appointment to an officer or senior administrative position shall be advised of this policy prior to their appointment.


The Secretary of the University has the responsibility to ensure that the procedures in this policy are satisfied and that the employees affected by this policy are informed of their responsibilities.  The Secretary of the University will maintain a list of positions covered by this policy.


Contact the Secretary of the University or General Counsel if you have any questions about this policy or if you would like more information.


Annual Certificate of Compliance (Word Doc)