¹ú²úAV

Purpose

The purpose of this policy is to:

• Provide examples of conduct which is deemed to constitute an actual or apparent conflict of interest. This list is not intended to be all-inclusive, and other activities or relationships may also constitute a conflict of interest depending on the circumstances.
• Describe the process by which disclosure of actual, potential, or apparent conflicts of interest are to be made by ¹ú²úAV employees or representatives.
• Describe enforcement of the conflict of interest policy.

Definition

For the purpose of this policy, the following definition applies. Conflict of interest means the existence of an employee's financial or personal considerations which may, or may appear to, impair or compromise the performance of the employee's duties as a ¹ú²úAV employee for or on behalf of ¹ú²úAV.

Types of Conflict

A conflict of interest, or apparent conflict of interest, exists when an employee or other person acting for or on behalf of ¹ú²úAV:

• Seeks personal gain through their employment or relationship with ¹ú²úAV Community College; or
• Engages in outside employment, consulting, business, or other activities that:
  • Impair the individual's ability to fulfill their obligations to ¹ú²úAV; or
  • Compromise, or reasonably appear to compromise, the individual's judgment in carrying out duties and responsibilities on behalf of ¹ú²úAV.

Personal Gain

The following are examples of conduct which present a conflict of interest when there is personal gain to the employee or a member of their family, friends, or others with whom they are associated. A person uses, or attempts to use:

• Their position with ¹ú²úAV to achieve a material or financial benefit for themself, family, friends, or others.
• ¹ú²úAV property, resources, or services, including but not limited to animal feed, facilities, offices, office supplies, telephone, equipment, and computing resources, for personal and private purposes to achieve a material or financial benefit for themself or others.
• Employees, students, contractors, or volunteers to achieve a material or financial benefit for themself or others.
• Any confidential information acquired in connection with ¹ú²úAV related activities or employment to achieve material or financial benefit for themself or others, or for unauthorized purposes.
• Directly or indirectly solicits, receives, or accepts anything of more than nominal value from any person or organization seeking to do business with or have an association with ¹ú²úAV.

Potential Exceptions

• Registration for an event at which the employee is making a presentation or providing a service, as an employee of ¹ú²úAV, to the event sponsor.
• Promotional items, such as coffee cups, pens, pencils, mouse pads, and similar items.
• Textbooks, software, and instructional materials to be reviewed by teaching faculty.
• An award, plaque, certificate, memento, or similar item given in recognition of the employee's charitable, civic, professional, personal, private, public, or political achievements.
• Food or beverage of nominal or reasonable amount given to or consumed by an employee at a single meal or event.

The President or their designee may grant additional exceptions, in writing, when they determine, based on the facts presented:

• The benefit accruing to the individual is of nominal value; and
• The exception will not impair either the individual's or ¹ú²úAV's ability to conduct business ethically, fairly, and impartially; or
• The requested exception is a common and generally accepted practice in public higher education institutions.
• The benefit received to the College exceeds the cost of the benefit provided to the employee.

Other Employment and Activity

The following are examples of non-¹ú²úAV employment or activity, either with or without compensation, which impairs the ability of an individual to perform their obligations as an employee or representative of ¹ú²úAV:

• Employment or other activity which occurs at times during which the employee normally is to perform their obligations for ¹ú²úAV.
• Employment, without the approval of the supervising Vice President, in a teaching capacity on a full-time or part-time basis with a secondary or another higher education institution.
• Employment or activity individually or with another person or entity providing goods or services which are in competition with goods or services provided by ¹ú²úAV Community College.

Disclosure

Disclosure Advice

Any person who is in doubt whether they are confronted with an actual or potential conflict of interest should seek the advice of their supervisor or supervising Vice President for their position to determine if the interest could conflict with the person's obligation to ¹ú²úAV. Employees are encouraged to disclose any potential conflict of interest out of an abundance of caution to ensure transparency and maintain the integrity of the College's operation.

Annual Disclosure

All employees or Trustees of ¹ú²úAV shall annually submit a completed Annual Conflict of Interest Disclosure Statement to the Director of Human Resources.

Enforcement

The ultimate responsibility for enforcement of this policy is the President, or their designee.

Violations of the policy or regulations include, but are not limited to:

• The failure to file timely disclosures.
• Filing incomplete, erroneous, or inaccurate disclosures.
• Failure to comply with prescribed procedures for managing or resolving conflicts or potential conflicts of interest.
• Violations shall subject the person to disciplinary sanctions which may include, but are not limited to, suspension from or termination of employment.
• The use of the employee's or individual's official title of employment or the ¹ú²úAV Community College's name, or any of the College's component parts, including any of the College's graphics, in any situation other than in the conduct of official ¹ú²úAV Community College business.
• The use of any ¹ú²úAV resource, including but not limited to ¹ú²úAV Community College stationery, the College's address, phone number, fax number, or electronic mail address as a contact point for personal or private business use.
• The use of the College's name, its tax-exempt status, or its tax-exempt number to purchase goods or services for personal or private business use.
• The use of ¹ú²úAV resources in such a way as to interfere with, or cause harm or damage to another person, institution, or company within or outside the ¹ú²úAV community.
• The use of ¹ú²úAV resources, property, equipment, or personnel for personal gain in a manner that does not provide a substantive benefit to the College.