Conflict of Interest

All college employees have an obligation to conduct college-related business transactions without actual, potential or perceived conflicts of interest. In accordance with this policy, college employees shall at all times act in a manner that is consistent with their position and shall take all necessary precautions to avoid any actual or potential conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a college decision that may result in a direct or indirect personal gain for that employee or for his or her family member, friend, or associate as a result of that college decision. For purposes of this policy, a family member 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.

Business dealings with outside firms also should not result in unusual gains for those firms and shall not result in any gains for college employees, including kickbacks, bribes, bonuses, fringe benefits, promises of employment or other windfalls designed ultimately to benefit either the outside firm, the employee(s) involved, or both.

Details and Employee Obligations

Any employee who has any influence on transactions involving college purchases, contracts, leases, or business matters must disclose the existence of any actual or potential conflict of interest to his or her department head as soon as possible so that safeguards can be established to protect all parties.
Specifically, any employee who is offered a gift or a series of gifts of $100 or more in value, from any individual or entity who might possibly gain from that gift, must report that gift to his/her supervisor and ultimately to the relevant PES member in order to assure that the gift does not constitute a conflict of interest. Employees should be aware that there are certain circumstances, such as during a bidding process, that a gift of any size would represent a conflict of interest. In addition, such an employee must also refrain from further participation in the transaction until such time as the actual or potential conflict can be reviewed and resolved.

Any employee who violates this policy will be subject to disciplinary action up to and including termination.