Conflict of Interest Policy

The purpose of the following policy and procedures is to prevent the personal interest of employees from interfering with the performance of their duties to the University, or result in personal financial, professional, or political gain on the part of such persons at the expense of the University.

Definitions: Conflict of Interest (also Conflict) is a conflict, or the appearance of a conflict, between the private interests and official responsibilities of a person in a position of trust. Persons in a position of trust include employees and officers. An Officer is the President, Vice President, or Vice President for Intercollegiate Athletics. An employee is a person who receives all or part of her/his income from the payroll of the University.

POLICY AND PRACTICES

1. Full disclosure, by notice in writing, shall be made by the interested parties to the Vice President for Financial Affairs in all conflicts of interest, including but not limited to the following:
   1. An employee in a supervisory capacity is related to another employee whom she/he supervises.
   2. An employee, or a member of an employee’s family (which for purposes of this provision shall be a spouse, parent, sibling, child or any other relative if the latter resides in the same household as the employee) receives payment from the University for any subcontract, goods, or services other than as part of her/his regular job responsibilities.
2. Following full disclosure of a possible conflict of interest or any condition listed above, the Vice President for Financial Affairs shall determine whether a conflict of interest exists and, if so, shall inform the President. The President shall authorize or reject the transaction or take any other action deemed necessary to address the conflict and protect the University’s best interests.
3. An interested officer or employee shall not participate in any discussion or debate of the President’s Cabinet, or any University committee or subcommittee in which the subject of discussion is a contract, transaction, or situation in which there may be a perceived or actual conflict of interest. However, they may be present to provide clarifying information in such a discussion or debate.
4. Anyone in a position to make decisions about spending resources (i.e., transactions such as purchases or contracts) – who also stands to benefit from that decision – has a duty to disclose that conflict as soon as it arises (or becomes apparent); she/he should not participate in discussions preceding that decision.