Policy Information

Issuing Office

The Board of Trustees (the “Board”) of Liberty University (together with its colleges, schools, affiliates, divisions, and subsidiaries, the “University”).

Affected Parties

Trustees, officers and employees of the University.

Policy

As a distinctively Christian academic community, members of the Liberty University community are expected to act as ambassadors for Christ. This means conducting themselves not only ethically and in compliance with applicable laws, regulations, and University policies, but also acting with utmost integrity and in a manner that is above reproach in all aspects of their work. This Code of Business Conduct (this “Code”) is designed to promote a high standard of ethical conduct for the University’s trustees, officers and employees in the operation of the University and is in addition to specific University policies that prescribe rules for day-to-day conduct.

Shared Expectations

Liberty University is committed to modeling to all how a Christ-centered institution should operate. The University expects its trustees, officers and employees to exercise good faith in all interactions touching upon their duties to the University. The University expects its trustees, officers and employees to:

Act with integrity – Trustees, officers and employees are required to act honestly, with each other, with the University and when representing the University, and must do so in compliance with applicable laws, regulations and University policies. However, the University’s expectation of integrity goes beyond any minimum requirements of law or policy and requires faithfulness to the University’s moral and Biblical principles.

Be honest and open – Trustees, officers and employees are required to be honest and free from fraud or deception in their dealings on behalf of the University. Obligations of honesty and transparency apply to financial matters, and records and reports of the University’s assets and transactions, as with all University documents, should be accurate, clear and complete. Obligations of honesty and transparency also require correcting false or misleading statements and records and require responding completely to inquires of investigators and auditors authorized by the University.

Demonstrate good stewardship – Trustees, officers and employees are required to carefully steward the University’s resources, using them for the benefit of the University and in compliance with applicable laws and regulations, and also without waste or extravagance.

Avoid conflicts of interest – Trustees, officers and employees are required to act in a manner consistent with their responsibilities to the University and to avoid circumstances where their financial or other personal ties to outside organizations could present an actual or potential conflicts of interest. University resources should not be used for personal gain, and when conflicts of interests arise, they must be properly reported.

Protect rights of privacy and confidentiality – Trustees, officers and employees are required to respect the privacy and confidentiality rights of others. Trustees, officers and employees are required to safeguard in compliance with applicable legal, contractual and policy obligations the various types of confidential information they come into possession of in the conduct of their work, including information that relates to students, other community members, personnel records and actions, and financial and contractual arrangements.

Support equity and inclusion – Trustees, officers and employees are required to foster a culture of Biblical based diversity, equity and inclusion, showing respect for all members of our community and treating all persons with impartiality, as equals before God. Trustees, officers and employees may not discriminate on the basis of any legally protected status applicable to Liberty University and should seek righteousness by opposing any such discrimination.

Take responsibility – Trustees, officers and employees must take responsibility for their own actions.

Trustees, officers and employees are expected to respect and act in harmony with the University’s Statement of Mission and Purpose and its Doctrinal Statement in all that they do on behalf of the University.

Reporting

Trustees, officers and employees are required to report, in good faith, to the University breaches, or reasonably suspected breaches, of this Code and of other University policies that cover ethical conduct. The University encourages the use of internal resources for reporting conduct, and many of the University’s specific policies have provisions for reporting of unethical conduct or conduct that violates law, regulations or policies. Reports that fall outside of existing policies, or for which there are no specified procedures, should be brought to the attention of the appropriate University administrator (or that administrator’s supervisor, when more appropriate). Alternatively, reports of violations or suspected violations can be brought to the attention of the University’s Internal Auditor. (Any reports with respect to the University’s Internal Auditor should be brought to the attention of the University’s General Counsel.) Trustees, employees and officers making reports may also choose to use any of the methods below to report any breaches of this Code anonymously:

• in writing to Liberty University, Attn: Internal Auditor, 1971 University Blvd. Suite 2618, Lynchburg, VA 24515; or
• by accessing the independent third party reporting service, Conversant, at Convercent.com/report and submitting a message. The website is managed by an outside, independent service provider. Individuals submitting reports are able to submit a report on an anonymous and confidential basis and are not required to divulge their name.

All reports that relate to alleged breaches of this Code by the President, General Counsel, Chief Financial Officer or Internal Auditor will be promptly disclosed to the Chair of the Audit Committee of the Board, who will direct the process for investigating and addressing such complaints.

This Code is not intended to be a substitute for the University’s processes for addressing complaints under the University’s applicable human resources policies, for reporting problems with colleagues, co-workers, or supervisors, for filing complaints of employment discrimination or harassment, for requesting accommodations or medical exceptions, for student requests for refunds, for student complaints and appeals regarding grades or other student-related academic issues, for health and safety complaints, for NCAA rule violations and for Title IX concerns and violations, all of which should be handled in accordance with the University’s other policies, including as set forth in current employee and faculty handbooks. Those polices are designed to provide individuals with certain procedural protections appropriate to the nature of such complaints.

No Retaliation

Trustees, officers and employees who come forward in good faith with reports about potential violations of this Code by others whether the report is specifically under this Code or otherwise made to an appropriate University administrator, or who participate in a resulting investigation in good faith, shall not be subject to retaliation for making such a report or participating in such investigation.

“Good faith” when reporting under this Code means an actual and reasonable belief that a beach of this Code has or may have occurred. A report is not in good faith if it is made maliciously, with knowledge that the report is false, with reckless disregard for the truth of the report, or with willful ignorance of facts that would disprove the allegation.

Procedures and Other Policies¹

University employees who have questions about the application of this Code to a particular situation should seek advice from the General Counsel. This Code is not intended to modify or limit the applicability or enforcement of specific University policies. Trustees, officers and employees should be aware of and comply with the specific University policies that apply to their roles, including applicable employee or faculty handbooks, codes of conducts for particular schools or departments, policies on conflicts of interest and commitment and whistleblower policies. Questions about the interactions of multiple policies should be directed to a supervisor or the General Counsel.

This Code is a statement of certain fundamental principles, policies and procedures that govern Trustees, officers and employees in the conduct of the University’s business. It is not intended to and does not create any rights in any employee, customer, supplier, competitor, or any other person or entity.

Sanctions

Trustees, officers or employees who violate this Code, including by engaging in retaliation, will be subject to disciplinary action, up to and including termination.

Revision History

Adopted as of November 5, 2021

1. The General Counsel is empowered to authorize updates to this section and references to other policies and procedures (including the last paragraph under Reporting) from time to time to reflect current University policies.