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Name: Conflicts of Interest Policy - Employees
Responsible Office: Business Office

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff

Policy Overview:

Issued: 06-21-2023
Next Review Date: 06-28-2024
Frequency of Reviews: Annually

This policy requires all employees to act solely in the best interests of the organization when making decisions and exercising their authority.  To this aim, the policy establishes procedures for disclosing and managing a financial interest or other relationship that results in a potential conflict of interest involving any arrangement, decision, or transaction involving the University.  

Applies to all employees in management, finance, research, or other designated positions.  This policy supplements the ethical principles set forth in the University’s Ethical Code of Conduct policy and implements disclosure requirements established under this policy, the University’s Excess Benefit Transactions policy, and the Financial Conflicts of Interest in Research policy.




Conflict of Interest

Means any actual or perceived Conflict of Interest.  An actual Conflict of Interest will occur when an employee’s personal interests (including Family Members) involve a relationship or association with another person or organization that may, directly or indirectly, influence the employee’s ability to act in the best interests of the University.  A perceived or apparent Conflict of Interest occurs when a reasonable person with knowledge of the circumstances would question the employee’s objectivity or ability to act in the best interests of the University. 

Controlled Entity 

Any entity where a Disqualified Person or Employee, together with any Family Member(s), owns more than 35% voting power of a corporation, more than 35% profits interest of a partnership, or more than 35% beneficial interest in a trust or estate. 

Interested Employee 

An employee who has an actual or perceived Conflict of Interest in connection with any University arrangement, decision, or transaction.  For purposes of this policy references to Interested Employee include a Controlled Entity or Family Member 

Family Member 

An Interested Employee’s spouse or domestic partner; sibling (whole or half-blood); descendant (birth or adoption); grandchild; and the spouse or domestic partner of any sibling or descendant of the Interested Employee. 


All employees are required to exercise due care and loyalty when making decisions and discharging their duties to advance the University’s best interests and the public good.  Administration and employees are expected to avoid, disclose, and manage Conflicts of Interest to protect the University’s assets and reputation. 


University employees must follow the following guiding principles for avoiding and managing Conflicts of Interest: 

  1. Promptly disclose conflicts of interest as soon as a conflict arises and abstain from discussion and voting on related matters.
  2. Avoid accepting gifts, favors, or hospitality of material value from persons or entities having or seeking to have a business relationship with the University.
  3. Maintain confidentiality of sensitive information (e.g. non-public financial information, personnel decisions, strategic plans, pending transactions, strategy, legal and compliance matters).
  4. Refrain from attempting to influence decisions where a conflict of interest exists with trustees, officers, or employees.
  5. Resist personal gain, unfair advantage, or the advancement of personal or dual interests (e.g. those of a Family Member/Controlled Entity).
  6. The University will avoid business or financial transactions with trustees, officers, and their Family Members unless, after appropriate due diligence, it is determined and documented that the transaction will result in a clear benefit to the University, involves fair market value consideration, no other reasonable alternative is available, and any Conflicts of Interest can be effectively managed.
  7. Any offer of employment to the Family Member of a trustee, officer, or employee must be reviewed and approved by the Chair, Board of Trustees, President, and the General Counsel & Chief Compliance Officer.
  8. Interested Employees who have disclosed a potential Conflict of Interest must not directly or indirectly participate in any discussions relating to a pending business arrangement, decision or transaction involving the University.  The Vice President Finance, Chief Financial Officer and the General Counsel, Chief Compliance Officer will advise the Employee’s manager, dean, or appropriate unit leader to ensure that an acceptable management plan and/or steps are initiated to mitigate Conflicts of Interest and protect the integrity of the University’s business affairs and interests.


I. Disclosure 
  1. The Business Office will annually distribute and collect a consolidated Conflict of Interest and Commitment Disclosure Form which contains standard disclosure requirements for all employees in covered positions  in addition to specific disclosures requirements for employees engaged in federally sponsored research.  Human Resources will coordinate disclosure for all new employees at the time of hiring.  A University employee has an affirmative duty to promptly disclose a Conflict of Interest to their supervisor, the University’s Business Office, or the University’s General Counsel & Chief Compliance Officer whenever it arises. 
  2. The Vice President Finance, Chief Financial Officer (or designee) and the General Counsel & Chief Compliance Officer will review Conflict of Interest disclosures and make recommendations to the appropriate unit leader or dean on the existence or absence of a Conflict of Interest and effective strategies for establishing a management plan. 
  3. The appropriate unit leader or dean is responsible for establishing a signed, written conflict of interest management plan approved by the Vice President Finance, Chief Financial Officer and the General Counsel & Chief Compliance Officer whenever a Conflict of Interest is identified. 
  4. Conflicts of Interest involving federally sponsored research will be disclosed and managed under the Financial Conflicts of Interest in Research policy. 
  5. Each University employee shall annually sign a statement which affirms that the employee has read and understands the Conflict of Interest Policy.   

II. Complaints

  1. Whenever reasonable cause to believe that an Employee has failed to disclose or made misrepresentations concerning a potential Conflict of Interest, the information should be promptly reported to the General Counsel & Chief Compliance Officer.  The General Counsel & Chief Compliance Officer (or designee) will initiate an investigation.  Upon completion of the investigation, the General Counsel & Chief Compliance Officer will submit a recommendation to Human Resources and the manager or appropriate unit leader that includes a determination on whether a violation of University policy occurred, a description of the relevant evidence and findings, and recommendations regarding remedial actions which may include disciplinary sanctions. 
  2. Complaints involving a researcher will be investigated and processed under the Financial Conflict of Interest in Research policy.  The University will not impose disciplinary sanctions involving faculty without first following applicable policies in the Faculty Bylaws. 
  3. Adequate documentation will be maintained to substantiate compliance with this Policy. 
  4. The President and General Counsel & Chief Compliance Officer will immediately report any complaints alleging a violation of this policy to the Chair, Board of Trustees, and the Chair, Board of Trustees. 




Vice President, Finance & CFO 

Annual COI Disclosure Form administration, policy advice,  compliance, management plans

General Counsel & Chief Compliance Officer/Office of the General Counsel

Training, legal advice, compliance, management plans

Assistant Vice President, Human Resources 

Training, obtain COI disclosures from new hires, compliance


Excess Benefits Transaction Policy 

Financial Conflict of Interest in Research Policy