Responsible Office: Human Resources Approved By: President's Council Approved Date: 11/1/2011 Effective Date: 11/1/2011 Category: Faculty and Staff Description/Purpose: The term “conflict of interest” pertains to situations in which financial or other personal considerations compromise, or have the appearance of compromising, an individual’s professional judgment and ability to perform his or her responsibilities at Saint Francis University. Details: The term "conflict of interest" pertains to situations in which financial or other personal considerations compromise, or have the appearance of compromising, an individual's professional judgment and ability to perform his or her responsibilities at Saint Francis University. All individuals who are covered under this Code should consider not only situations that are unacceptable, but also those situations that might involve the appearance of a conflict. A member of the University community may not profit or gain an unfair advantage at the expense of the well-being of the University as outlined below:
Conflict of Interest Disclosure Guidelines Should an employee, consultant, vendor, contractor, or volunteer believe he or she is involved in a matter or is engaged in an activity in which a conflict of interest may exist, he or she must promptly and fully disclose the conflict to the Vice President for Finance & Administration, refrain from further participation in the matter until it is resolved, and follow directions given by the University concerning the matter. If there is uncertainty whether an activity might violate this policy, or for answers to questions regarding this policy consult with the Vice President for Finance & Administration. All trustees and officers of the University shall disclose to the Board any possible conflict of interest at the earliest practical time. No Trustee shall vote on any matter, under consideration at a Board or committee meeting, in which such Trustee has a conflict of interest. The minutes of such meeting shall reflect that a disclosure was made and that the Trustee, who is uncertain whether he or she has a conflict of interest in any matter, may request the Board or Committee to determine whether a conflict of interest exists, and the Board or Committee shall resolve the question by majority vote. When possible, the question of potential conflict should be referred to the University's legal counsel for an opinion prior to the Board's vote. Trustees or officers who have declared or been found to have conflict of interest in any matter before the Board shall refrain from participating in consideration of the proposed transaction, unless for special reasons the Board or administration requests information or interpretation from the person or persons involved. The person or persons involved should not vote on such matters and should not be present at the time of the vote. Conflict of Interest Disclosure Statement Members of the University community who become involved in potential conflict of interest situations must complete a Conflict of Interest Disclosure Statement at the time they become aware of the potential for a conflict of interest. All members of the board of trustees, officers, president's council, deans, and selected staff (Director(s) of Physical Plant, Purchasing, Risk Management, and Athletics; Controller, Chief Information Officer) are responsible for filing an annual disclosure statement to disclose all business interests, affiliations and/or relationships that could reasonably give rise to a conflict of interest involving the University. Conflict of Interest Disclosure Statements are distributed by the Director of Human Resources who is responsible for ensuring that statements are completed and returned each year. For trustees and officers, the disclosure statements shall be provided to the Chairman of the Board, or in the case of the Chairman's disclosure statement, shall be provided to the Secretary of the Board. In the case of staff or others with significant decision-making authority, the disclosure statements shall be provided to the President. The President's Office shall maintain copies of all disclosure statements. A Conflict of Interest Disclosure Statement is available from the Office of Human Resources. Violations of Conflict of Interest Policy If the Board of Trustees or University has reason to believe that a member of the University community has failed to disclose an actual or potential conflict of interest, it shall inform the person of the basis for such belief and afford the person an opportunity to explain the alleged failure to disclose. If, after hearing the response of the individual and making such further investigation as may be warranted in the circumstances, it is determined that the individual has in fact failed to disclose an actual or possible conflict of interest, the Board of Trustees or University shall take appropriate disciplinary and corrective action. |