I. Introduction
The Conflict of Interest Policy describes the responsibility of all members of the university community to conduct the fiscal business of the university without even the appearance of impropriety.
This policy applies to all trustees, officers, faculty, and staff in defining the conditions of propriety which must prevail in administering the financial resources of the university in furtherance of its mission. This policy is in addition to any conflict of interest policy that may appear in the Staff Handbook or the Faculty Handbook.
II. Definitions
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Procedures and Regulations
University trustees, officers, faculty, and staff are expected to avoid even the appearance of impropriety when performing their duties, and must not use their positions or knowledge gained at the university to improperly influence decisions for their personal advantage or for the advantage of their families or friends.
No organization manager may expend university funds for personal gain.
III. Disclosure
University trustees, officers, faculty, and staff are expected to disclose to the appropriate university official as specified below any actual or potential conflicts of interest and should not initiate any contract or transaction to which the university is a party until approval is received.
When any interest on the part of a trustee, officer, faculty or staff member of the university or a member of his or her family poses a possible conflict with the trustee's, officer's, faculty or staff person’s university responsibilities, the trustee, officer, faculty or staff member shall promptly report the conflict to the attention of the other Trustees or the Officers of the university who are participating in or voting on the matter which poses the possible conflict, and that person shall abstain from participation in or voting on such matters.
The minutes of the meeting shall reflect that a disclosure was made and that the trustee or officer abstained from any participation in the matter.
Each trustee, officer, dean, and director shall annually disclose to the university any potential conflicts of interest by signing and submitting a university disclosure statement. Any faculty member who engages in sponsored research shall also annually disclose to the university any potential conflicts of interest by signing and submitting a university disclosure statement. The responsibility for obtaining the annual disclosure shall be assigned as follows:
For the Board of Trustees and the officers of the university: The Secretary of the Board
of Trustees
For the faculty: The Provost
For all staff members: The Vice President for Finance and Treasurer
Any disclosure of a conflict of interest by a University Trustee or Officer shall be reviewed by the Audit Committee of the Board of Trustees.
It is the responsibility of any employee to report to the Internal Auditor any potential conflict of interest of which he or she becomes aware affecting transactions to which the university is a party. The Internal Auditor will investigate and report the results and findings to the Vice President for Finance and Treasurer or other university officer as appropriate.
IV. Procurement
An employee may not purchase or influence the purchase of goods or services for university use from a firm or organization if the employee or his/her family would receive financial gain, without disclosing such interest in writing to their immediate supervisor and to the Purchasing Department.
V. Conditions of Possible Conflict of Interest
No individual within the scope of this policy shall participate in a transaction or procurement when the individual is employed by the outside party; has a pecuniary interest in the outside party; or, is negotiating or has an arrangement concerning prospective employment with the outside party.
VI. Employment
A member of the immediate family of an employee may not be assigned to a position in which the one would have direct or indirect administrative or supervisory responsibility for the other or to a position in the same office. “Immediate family” is defined as a spouse, child, including adopted and step child, parent, parent-in-law, sibling or legal guardian. This provision is effective for all personnel actions occurring after November 30, 1988 and is applicable to all regular or temporary, full- or part-time employees.
No organization manager may sign off on payroll/personnel forms that affect his/her own salary or approve reimbursement of his/her own expenses or those of a direct supervisor.
No employee or former employee having official responsibility for procurement transactions should accept employment with any bidder or contractor with whom he/she has dealt in an official capacity concerning procurement transactions for a period of one year after termination of the employee's university employment unless specifically waived by the Vice President for Finance and Treasurer. Employees in positions with these responsibilities will be required to sign an agreement to this effect as a condition of employment.
VII. Solicitation and Acceptance of Gifts, Travel, etc.
No individual within the scope of this policy shall solicit or accept money, gift, loan, advance, favor, special discount, or service of material value that might reasonably tend to influence him/her in the discharge of his/her duties.
Such individual shall not accept a business or personal trip paid for by the vendor, for any reason whatever, without first obtaining written approval from the Vice President for Finance and Treasurer. Acceptable circumstances for such travel (inspection, training on new equipment, etc.) must be established through the procurement process.
Finance: Finance