EMPLOYEE HANDBOOK

CONFLICT OF INTEREST

Employees are expected to avoid situations that create actual or potential conflict in which an Employee’s actions or loyalties are divided between personal and University interests or between University interests and those of another. A conflict of interest may arise in a wide variety of circumstances and may be direct or indirect. A conflict of interest arises whenever an Employee’s outside interests might affect or might reasonably be thought by others to affect an Employee’s judgment or conduct in matters that involve the University.

It is the University’s policy to forbid Employees from having a financial interest in any other business that competes with the University, except where such ownership consists of securities of a publicly-owned corporation regularly traded on the public stock market. The University’s policy also forbids engaging in, directing, managing, or consulting for a business or businesses that compete with the University without the express written consent of the President/CEO or Owner. If an Employee thinks that there is a possibility that they may have a conflict of interest, it is the Employee’s responsibility to notify the President/CEO or Owner and request approval before becoming engaged in outside activities or relationships that could violate this Policy.

While it is not feasible to describe all possible conflicts of interest that could develop, some of the more common conflicts, from which Employees should refrain, include the following:

  • Accepting personal gifts or entertainment from competitors, customers, suppliers, or potential suppliers;
  • Working for a competitor, supplier, or customer;
  • Engaging in self-employment in competition with the University;
  • Using proprietary or confidential University information for personal gain or to the University’s detriment;
  • Having a direct or indirect financial interest in a competitor, customer, or supplier (except that ownership of less than one percent of the publicly traded stock of a corporation will not be considered a conflict);
  • Using the University’s assets or labor for personal use;
  • Acquiring any interest in property or assets of any kind for the purpose of selling or leasing it to the University;
  • Committing the University to give its financial or other support to any outside activity or University; and
  • Developing a personal relationship with an Employee of the University or any of its customers or vendors that might interfere with the exercise of impartial judgment in decisions affecting the University or any Employee of the University.

Violation of this Policy by engaging in any of these activities or any other activity that the University deems to be a conflict of interest, or creates the appearance of a conflict of interest, will result in disciplinary action, up to and including immediate separation of employment.