The Catholic University of America

Conflict of Interest Policy for Staff and Faculty 

Approved by: Board of Trustees
History: Issued              -- March 14, 2002
  Revised            -- September 10, 2012
  Last Reviewed -- 
Related Policies:
Additional References: Conflict of Interest Tutorial
Responsible Official: Vice President for Finance and Treasurer tel. (202) 319-5606


I.     Policy Statement

Staff and faculty employees (“employees”) are expected to avoid even the appearance of impropriety in the performance of their duties on behalf of the University.  Employees must carry out their University duties and administer University resources only in furtherance of the University’s mission and interests, and may 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. 

Employees must disclose potential conflicts of interest in writing and obtain advance approval to proceed before initiating any transaction or engaging in any decision on behalf of the University.  Failure to disclose potential conflicts may result in University disciplinary action up to and including termination.

This policy describes common conflict situations, sets forth University expectations regarding the avoidance of conflicts of interest, and describes the mandatory processes for disclosing potential conflicts of interest.

II.     Definitions

A.     Conflict of Interest means a situation in which the interests of an employee and the interests of the University diverge, or may appear to diverge.  Conflicts often arise when there is the potential for an employee, the employee’s immediate family members, or the employee’s friends to benefit personally as a result of the employee’s involvement in the University activity or decision. Conflicts also may arise when an employee has non-University interests or duties that could possibly influence how the employee acts in their duties on behalf of the University. Actual impropriety is not necessary for a conflict of interest to arise.  The appearance or potential for a conflict can be just as damaging as actual self-dealing. 

B.    Employee for the purposes of this policy includes staff members (whether full-time, part-time, or temporary) and faculty members (whether full-time, part-time or adjunct).

C.    Financial Interest means anything of monetary value, whether or not the monetary value is readily ascertainable.

D.    Immediate Family Member means an Employee’s spouse, child (including adopted and step child), parent, parent-in-law, sibling, legal guardian, or household member.

III.     Conflict Situations

This policy sets forth common conflict of interest situations and the University’s expectations regarding employee avoidance of conflicts.  However, no policy can address specifically every conceivable situation that might entail a conflict of interest.  As a general principle, employees should avoid any actions or situations that might result in or create the appearance of using their association with the University for private gain, according unwarranted preferential treatment to any outside individual or organization, losing independence or impartiality, or adversely affecting the University's reputation, mission, or public confidence in the University's integrity.

Employees who are uncertain whether a situation poses a potential conflict should discuss the situation in advance with their supervisor, the Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU), or the Office of General Counsel (tel. (202) 319-5142).

A.     Financial Conflicts

Employees must maintain independence from vendors, contractors and others doing business with the University. 

Employees may not directly or indirectly expend University funds for personal gain.  Absent advance written disclosure and approval, employees may not purchase or influence the purchase of equipment, goods or services for University use or with University funds from an individual, firm or organization: 1) in which the employee or his/her immediate family members or friends have a financial interest; or 2) if the employee also is employed by, or is negotiating or has an arrangement concerning prospective employment with that individual, firm or organization. 

Employees may not accept money, gratuities, gifts, favors, entertainment, or reimbursement of expenses from individuals, firms or organizations with which the University has business dealings if acceptance might reasonably be interpreted as an attempt to influence the employee in the conduct of their duties.  See the Gifts from Contractors/Vendors Policy for further information and requirements.

B.     Externally-Funded Research

Disclosure and management of potential conflicts of interest with respect to externally-funded research projects are governed by the Faculty Handbook - Part III, Employment Conflicts and Misconduct, Conflicts of Interest Policy - Externally Funded Research.

C.     Employment Conflicts

In accord with the Employment Practices and Procedures Policy, employees and their immediate family members may not be assigned to positions in which one would have direct or indirect administrative or supervisory responsibility for the other, or be in a position to influence the terms or conditions of the other person's employment.  Likewise, employees may not initiate or participate in institutional decisions involving a direct benefit (e.g. initial appointment or hire, retention, promotion, salary, leave of absence, etc.) to their immediate family members. 

Employees may not sign off on payroll/personnel forms that affect their own salary or approve reimbursement of their own expenses or those of a direct supervisor.

D.     Conflicts of Commitment and Loyalty

1.     Commitment

Faculty members’ outside employment, consulting and professional activities are governed by the Faculty Handbook - Part III, Employment Conflicts and Misconduct, Conflict of Commitment Policy and Faculty Handbook - Part III, Policies, Procedures and Services, Compensation from External Consulting.

Full-time staff employees 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 the University or the University's mission.

The approval of the staff employee’s supervisor must be obtained before accepting an additional assignment at the University other than the primary work assignment.

2.     Loyalty

Employees 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.

An employee may not use for personal gain, or other unauthorized use, any privileged information acquired in connection with the employee’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.)

IV.     Disclosure of Potential Conflicts

Conflicts of interest can best be defused or eliminated by advanced voluntary disclosure and independent review. In this way apparent or potential conflicts, as well as actual conflicts, may be avoided.  

In accordance with the processes set forth below, employees must disclose potential conflicts of interest in writing and obtain advance approval to proceed before initiating any transaction or engaging in any decision on behalf of the University. 

Failure to disclose potential conflicts may result in University disciplinary action up to and including termination.

All conflict of interest disclosures are held in the strictest confidence possible, and are shared on a need-to-know basis only.

A.     Ongoing Disclosure Requirement

Except where an alternative disclosure and approval process is specifically provided for as set forth in this policy, employees must report to the University’s Chief Ethics and Compliance Officer (tel. (202) 319-6170 or CUA-COMPLIANCE@CUA.EDU) any potential conflict of interest that may affect transactions or decisions to which the University is a party.  Disclosures must be made as soon as the employee becomes aware of the potential conflict. The Chief Ethics and Compliance Officer will review the disclosure and work with the employee and any other University official as appropriate in order to eliminate or manage the potential conflict.

B.      Annual Disclosure Process

Annually, designated employees are required to disclose any actual or potential conflicts of interest by submitting a University disclosure statement to the appropriate University official as specified below: 

1.    For faculty members: The Provost

2.    For staff members: The Vice President for Finance and Treasurer 

The annual disclosure process for University Trustees is governed by the Board of Trustees Conflict of Interest Policy.
The University’s Chief Ethics and Compliance Officer provides support to the Provost, the Vice President for Finance and Treasurer, and the Vice President for University Relations and Chief of Staff in administering the annual disclosure processes.