Conflicts of Interest


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. The purpose of these guidelines is to provide general direction so employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the Office of Human Resources for more information or questions about conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for the employee or for a relative as a result of ASC's business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts or leases, it is imperative that they disclose to an officer of ASC as soon as possible the existence of any actual or potential conflict of interest so safeguards can be established to protect all parties.

Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which ASC does business, but also when an employee or relative receives any kickback, bribe, substantial gift or special consideration as a result of any transaction or business dealings involving ASC.

Employees shall disclose, in writing, to their 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. This includes the employee 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.

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

  • 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.

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

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

  • Accepting gratuities or special favors from any outside concern that does, or is seeking to do, business with the College; or extending gratuities of special favors to employees of the College under the circumstances that might reasonably be interpreted as an attempt to influence 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.


Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which ASC wishes to operate.

Annually, all budget managers are required to sign a Conflict of Interest Compliance form acknowledging their agreement to comply with the policy (see below).

The College welcomes comments or questions regarding this policy. Any employee of Agnes Scott who wishes to report an alleged violation is encouraged to do so without fear of retaliation. Question, comments or alleged violations should be reported to the director of human resources at (404) 471-6435.

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CONFLICT OF INTEREST COMPLIANCE

I have read and understand the Conflict of Interest policy in the Staff and/or Faculty Handbook. I certify that I am in compliance, and have had no conflict of interest for fiscal year ________.

I do not anticipate any actions that would result in a conflict of interest in the future; however, if such a conflict arises I understand it is my responsibility to notify the appropriate personnel as outlined in the Staff and/or Faculty Handbook.

_____________________________________

Employee's Signature

______________________________________

Title

_____________________________________

Name (Please Print)

______________________________________

Date

Please return the completed form to Human Resources by ___________ .


Policy No.  108  Issued  1/1/2004