Conflicts of Interest

as revised on February 16, 2011

Situations may arise in which the private financial or business activities of an employee may conflict with the employee’s obligations to the College, or with the best interests of the College, or may raise a reasonable question of concern in this respect.

Each employee shall disclose, in writing, to his/her immediate supervisor and the Office of Human Resources, any direct or indirect interest which such employee has or may have in any existing or proposed transaction to which the College is a party, by reason of such employee also being a party thereto, or being an officer, director, partner in or personally significant owner of a corporation, partnership, or other business entity which is a party to such transaction.  The Office of Human Resources will contact the officer in charge of the respective area to determine what actions are deemed necessary.  Where applicable, governmental regulations regarding conflict of interest shall be followed, as shall other college policies that govern sponsored programs.

Situations that constitute conflicts of interest include, but are not limited to, the following:

1.    Holding, either directly or indirectly, a position or financial interest in an outside concern that provides services competitive with services rendered by the College, or an outside concern from which the College secures goods or services if the employee is involved in or may influence the ordering of such goods or services.

2.    Competing, either directly or indirectly, with the College in the purchase or sale of property or property rights, interests, or services.

3.    Disclosing or using nonpublic information obtained through college employment for personal profit or gain or for the profit or gain of others.

4.    Accepting gratuities or special favors from any outside concern that does, or is seeking to do, business with the College; or extending gratuities or special favors to employees of the College under the circumstances that might reasonably be interpreted as an attempt to influence the recipients in the performance of their duties.  This does not include the acceptance of items of nominal or minor value that are clearly tokens of respect or friendship and not related to any particular transaction or activity of the College.

To maintain your compliance with the Conflict of Interest policy, please re-review the policy on this web page annually as explained in the annual Conflict of Interest email.