Conflict of Interest
Employee Conflict of Interest Policy Disclosure
Each employee shall annually disclose any affiliation with any outside organization which may lead to the appearance of or actual conflict of interest. Such an affiliation would ordinarily include (a) the holding of the position of officer, director, trustee, partner, employee or regularly retained agent of such organization or; (b) the expected receipt in the current or a future year of remuneration for services from such organization in excess of $500. For example, any employee who, in the course of their duties for the University, has control over or affect upon any decision to engage in a business transaction with such an affiliated outside organization, must disclose his/her relationship to this organization by a close relative (e.g., spouse, child, sibling, parent or parent-in-law) should also be disclosed prior to the transaction.
Conflict of Interest Policy for Reporting Procedures
On an annual basis by every December 31, this policy will be reviewed with the University community as a basis for reaffirming the commitment of the University to the standards of conduct expected of all in the performance of their duties
At the beginning of each calendar year, the President, Provost and Vice Presidents will prepare a list of every administrator, faculty, staff or student who falls within the scope of this policy. The list must include all employees who, on a regular basis, have both the authority and responsibility to commit the University to contractual relationships, or commit or encumber the funds of the University, whether general operating, restricted or designated in nature. At a minimum, the list will include all employees who hold the title and/or responsibility accorded to the director level positions and above and any others specifically designated by the President, Provost or Vice President of the University.
Annually, all employees who have been identified will receive a directive from the President or their designee to complete an annual disclosure statement form. Each individual selected to complete the form will be required to complete and sign the disclosure statement, identifying any potential or existing conflicts of interest or attesting to the fact that there were no areas of potential or existing conflicts of interest will be returned to the President, Provost, Deans or respective Vice Presidents for their initial review. All disclosure statements will be forwarded to the President's designee who will tabulate the response and comments; initiate any required follow up and provide a detailed report to the President and the Audit Committee of the Board of Trustees.
All individuals listed will be responsible for providing notification to the President, Provost or appropriate Vice President of any instances of conflict of interest which may occur in the interim period between the dates of regular reporting. Each individual is also responsible for reporting potential or existing conflicts involving other personnel subject to this policy of which the individual may become aware. Failure to disclose any potential or existing conflict of interests will result in disciplinary action.
In addition to the code of conduct and conflict of interest policies contained herein, there are additional policies and employee responsibilities as follows:
- Conflict of Interest in Externally Funded Projects (Lakeside Campuses)
- Conflict of Interest Research Policy (Maywood Campus)
- See Anti-Nepotism Policy and Additional Human Resource Policies
- Information Technology Policies
- College Loan Code of Conduct (PDF)
- Policy for Financial Records Retention
Board of Trustee Conflict of Interest Policy
The above policies and perhaps other policies involving specializations may require separate and unique reporting of conflicts of interests and must also be followed.
No employee shall, for personal gain or for the gain of others, use any information not available to the public that was obtained as a result of service to the University (e.g., selling or divulging University phone-books, etc. to outside parties).
Gifts and Favors
No employee shall solicit or accept for personal use, or for the use of others, any gift, favor, loan, gratuity, reward, promise of employment or any other thing of monetary value that might influence or appear to influence the judgment or conduct of the employee regarding University business or policy. Employees may accept occasional unsolicited gifts or favors (e.g., business lunches, Christmas baskets, etc.) provided the gifts or favors have a cumulative market value of under $250., are customary in the industry, and will not influence or appear to influence the judgment or conduct of the employee. The restrictions in this paragraph regarding a specific gift or favor, may be waived, in writing, by the appropriate Provost or Vice President. Such an exemption must be in writing with a statement of the pertinent reasons for exemption.
Frequently Asked Questions
All members of the University community are subject to the code of conduct. This includes trustees (under a separate conflict of interest policy), officers, faculty and staff as well as individuals who are doing business with the University. Students are not subject to this code of conduct unless they are employed by the University. Students are subject to policies set by the dean’s office.
Members of the University community are already subject to laws, regulations and internal policies. However, they do not govern all behavior. We felt it was important for our stakeholders to understand exactly how they can expect us to conduct ourselves. Our code of conduct is basically a set of standards describing the behavior we expect of members of the University community. In addition, as a recipient of federal awards, we are required to have a code of conduct.
Our code of conduct doesn’t change our daily responsibilities. It is a restatement of guidelines we believe the members of the University community are already following. It articulates the way we strive to conduct ourselves. Clearly, no code of conduct can guarantee the prevention of wrongdoing. But a code of conduct, coupled with the appropriate supporting activities, is considered a “best practice” that can help to sustain a culture in which integrity is valued and promoted through our daily work.
Members of the University community who violate the code of conduct, or other policies, will be subject to disciplinary action-up to and including termination. A key part of developing the code has been to ensure that all decentralized units take steps to ensure that their people understand and comply with the code.
No. We encourage you to report potential violations. We do not tolerate retaliation. We will take disciplinary action if retaliation occurs.