Officer Accountability Policy

Effective Date:

September 1, 2016

Supersedes:

Officer and Senior Executive Accountability Policy

Policy Review Date:

3 Years from Effective Date

Issuing Authority:

Research Foundation President

Responsible Party:

Chief Financial Officer

Contact Information:

518-434-7050

rffinance@rfsuny.org

Reason for Policy

The Officers of The Research Foundation for The State University of New York ("Research Foundation" or "RF") are in positions of authority. They are accountable for expenditure of certain RF funds and management of RF activities to accomplish their assigned responsibilities. This policy establishes the requirements for independent review and approval of transactions that have a professional or personal impact on these Officers to assure compliance with established RF policies and procedures.

Statement of Policy

Officers must obtain the appropriate level of review and approval for all Officer Transactions. The required reviews and/or approvals are set out in the table in the "Responsibilities" section of this document.

Officer Transactions must not be reviewed or approved by the impacted Officer, nor a person who reports to or is a subordinate of that Officer. The person authorized to review or approve Officer Transactions must be an individual with sufficient knowledge to evaluate the appropriateness of the Officer Transaction.

Each operating location must maintain records that document Officer Transactions. While the procedures and specific content and structure of the file(s) may vary at individual operating locations, all Officer Transactions must be documented to show the date and type of Officer Transaction and the review and approval of the Officer Transaction by the Authorized Signer(s).

The Campus President has authority to be the Authorized Signer for all Officer Transactions that pertain to the RF Operations Manager at each SUNY campus. If a Campus President chooses a designee, the Campus President must notify in writing the RF Office of Compliance Services.

If an Officer also serves as a Principal Investigator (PI) on a sponsored award or serves as an officer or director of an Affiliated Entity, transactions executed when acting in those roles are not Officer Transactions and may be processed consistent with the normally applicable policies and procedures utilized for sponsored programs administration or technology transfer. However, mechanisms must be in place to ensure compliance with the RF’s Conflict of Interest Policy.

Responsibilities

The following table outlines the responsibilities for compliance with this policy:

Responsible Party

Responsibility

RF Board of Directors

Make compensation determinations for the RF president.

Supervise the RF president.

RF President

Establish and approve all Compensation for other Elected Officers consistent with RF policy and practices.

Note: These determinations must be reviewed by the Board of Directors for reasonableness.

Review and approve Officer Transactions for (or on behalf of) other Elected Officers. The President may delegate this responsibility to another Elected Officer who is not benefited by the Officer Transaction subject to review.

As the Chief Executive Efficer, the President is the highest-ranking RF employee and must comply with all RF policies and procedures, including maintaining documentation of Time and Attendance, and travel and OTPS expenditures.

Chief Operating Officer

Review and approve Officer Transactions of Elected Officers, except the RF President, as applicable or as delegated by the RF President.

RF Chief Financial Officer

Review and approve Travel and OTPS Expenditures of the RF President and Officer Transactions of other Elected Officers, as applicable or as delegated by the RF President.

RF Officers

Obtain appropriate review and/or approval by an Authorized Signer for all of their Officer Transactions.

As delegated by the RF President, review and approve Officer Transactions of other Elected Officers other than the RF President .

Campus Presidents

Review and approve or delegate to an appropriate Authorized Signer the responsibility to review and approve Transactions for or on behalf of Officers (i.e. Operations Managers at his/her campus).

Authorized Signer

Review and approve Transactions for (or on behalf of) RF Officers.

Internal Audit Services

Periodically review and audit compliance with this policy. Specifically, a sample of transactions for all elected officers and a sample of appointed officers will be reviewed annually.

Compliance Office

Office of record to maintain signatory delegation documentation.

Definitions

Affiliated Entity is an organization that the RF serves as a corporate partner or corporate member. Refer to list of RF Affiliated Entities

Appointed Officer is an individual appointed by the RF board or RF President as an officer who is given the signature authority and administrative authority to perform executive duties. For the purposes of this policy an appointed Officer includes, Operations Managers at the operating locations of the RF and excludes individuals with delegated authority as appointed officers at the RF central office.

Compensation is any form of compensation the Officer receives for performing the designated role, including but not limited to the following: salary and wages; benefits; bonuses; and extra service compensation.

Elected Officer is an officer elected under the RF’s bylaws, including the Research Foundation’s President, Chief Operating Officer, General Counsel, Secretary, and Chief Financial Officer and excluding those appointed pursuant to Article IV Section 13 of the RF’s bylaws bylaws as appointed officers.

Officer is any Elected or Appointed Officer.

OTPS is "other than personal services" expenditures.

Travel and OTPS Expenditures are travel vouchers; procurement requests; authorizations; approvals; or expense reimbursement for travel, supplies, meals, or entertainment expenses used for (or on behalf of) an Officer.

Time and Attendance is exception reports or time sheets, in any form, indicating time worked, or leave taken (i.e., annual, sick, holiday), filed by an Officer.

Officer Transactions are the Officer’s Time and Attendance, Travel, and OTPS Expenditures, personnel decisions affecting the Officer, and any other transactions for (or on behalf of) such Officer.

Related Information

Travel Handbook

Unrestricted Fund Expense Policy

Conflict of Interest Policy

Code of Conduct

Records Management Policy

Time Reporting Policy

Forms

None

Change History

Date

Summary of Change

September 1, 2016

Removed senior executives from the policy. Some language was moved from the definitions section to the statement of policy. Language regarding exceptions to the policy was eliminated.

March 15, 2013

Include Compliance Office as office of record, responsibilities clarified, added sentence related to management plan for PIs and when serving on affiliated entities, added definition of Affiliated Entity, updated name to reflect senior executives and included them in the policy. Effective 3/15/2013

February 13, 2012

Officer Accountability Policy created.

 

 

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