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Employment - Staff
Conflicts of Interest

 

Approved by: The President and his Council 
History: Issued -- June 1, 1994
  Revised --Feb. 28, 2007
Additional History
Related Policies:
Additional References: On Preventing Conflicts of Interest in Government Sponsored Research at Universities; Conflicts of Interest Disclosure form and Questionnaire for Staff
Responsible Official: Associate VP/Chief Human Resources Officer 202-319-5050


I.  Policy
Employees of the university are expected to avoid even the appearance of impropriety in respect to the performance of their duties and must not use their positions or knowledge gained on the job to inappropriately influence decisions for the personal advantage of themselves, their family, or their friends.

Favorable social and business relations between the university and all segments of the community are important. Employees however, should not accept entertainment, gifts or favors provided by persons with whom the university has business dealings under circumstances which give the appearance that the donor intended to influence the employee's judgment or conduct. See the section on Gifts From Contractors/Vendors in the CUA Policy Manual.

Since involvement in activities which give the appearance of a conflict of interest is a serious matter, employees should discuss any potential conflict of interest with the department administrator before engaging in such activities. There are many kinds and degrees of conflict of interest and each situation must be judged on its own.

 

II.  Conflict Situations
Employees of CUA should neither initiate nor participate in institutional decisions involving a direct benefit (initial appointment, retention, promotion, salary, leave of absence, etc.) to members of their immediate families.

Regular administrative and professional staff members may engage in non-university employment, consulting, or professional practice only when the work will be performed outside university duty hours or while on leave from the university and the work will not interfere with the performance of professional duties and responsibilities to CUA. The approval of the department administrator must be obtained before accepting non-university work or an additional assignment at CUA other than the primary work assignment.

A university employee may not undertake or orient his/her work to serve the needs of another organization without disclosure of such an undertaking or orientation to the university.

A university employee may not purchase or influence the purchase of equipment, instruments, materials, other items or services for university use from a firm or organization in which the employee or his/her family would receive financial gain without disclosure of such interest.

A university employee may not transmit to a private firm or use for personal gain, any university or university-related work products, research results, materials, records, information, or other resources that are not made generally available to the public.

A university employee may not use for personal gain, or other unauthorized use, any privileged information acquired in connection with the staff member's university activities. (The term "privileged information" includes, but is not limited to, medical, personnel, financial, security records of individuals, or any records protected by statute; anticipated material requirements or price actions; and, knowledge of forthcoming programs or of selection of contractors or subcontractors in advance of official announcements.)

A university employee may not accept gratuities or special favors from any organizations with which the university does or may conduct business, or extend gratuities or special favors to employees of other organizations under circumstances which might reasonably be interpreted as an attempt to influence the recipients in the conduct of their duties. See the Finance Conflict of Interest Policy.

An administrative level or professional staff member is required to follow the recommendations of the statement "On Preventing Conflicts of Interest in Government Sponsored Research at Universities," issued jointly by the Council of the American Association of University Professors and the American Council on Education.

Questions regarding issues of potential conflict of interest should be referred to the General Counsel of the university for guidance and resolution.

 

 



Last Revised 08-May-09 12:08 PM.