Employee Conflict of Interest

Policy Statement

It is the policy of the University that Faculty and Staff avoid any conflict, or appearance of conflict, between personal interests and the interests of the University in dealing with any organization or third party. When Faculty and Staff are aware that such organization or individual (i) has or seeks to have a business relationship with the University, or (ii) has objectives or interests that may be adverse to the University's interests, Faculty and Staff are expected to avoid such conflicts of interest, to disclose any personal interest that may conflict with their obligations to the University, and to refrain from influencing any decision of the University on a matter in which such a conflict exists.

Reason for Policy

Faculty and Staff are presumptively considered to have a conflict of interest when they have an existing business relationship, family relationship, or a relationship with a provider of services that impairs or might appear to impair the individual's independent judgment in the discharge of responsibilities to the University, or receives, or may receive a material, financial, or other benefit from access to University information.

Who Is Governed by this Policy

Faculty and Staff

Policy

This policy is to be interpreted and applied in a manner that will best serve the interests of the University. In some cases, it may be determined that after full disclosure of a business or personal relationship between those concerned, the University's interests are best served by participation by utilizing/engaging the individual or business in such a relationship, despite the appearance of a conflict of interest.

All Faculty and Staff shall be advised of this policy during their onboarding to the University.  

Procedure: Disclosure of Conflict

Faculty and Staff must disclose any possible business, familial, or service relationships that reasonably could give rise to a conflict of interest involving the University, and to acknowledge, that they are acting in accordance with the letter and spirit of this Policy.

For all disclosures where there is, or appears to be, a conflict of interest, the Vice President of Finance and Administration and the Associate Vice President of Human Resources will review and make a final determination.

In the event that the Vice President of Finance and Administration and Associate Vice President of Human Resources deem there to be an actual conflict of interest, the following actions may be requested:

• Faculty and Staff will refrain from influencing any decision or action on the matter in conflict.
• The University will cease conducting business and/or transactions as to the persons or entity involved in the actual conflict.
• A neutral third-party will review the transaction and/or business relationships to determine that it is an arm’s length relationship and in the University’s best interests.

Ongoing Assessment of Potential Conflicts

Any members of the staff who are uncertain whether they have a potential conflict of interest in any matter, or who desires assistance in interpreting this Policy, may seek advice from the Vice President for Finance and Administration and the Associate Vice President of Human Resources.

Definitions

• Employment relationships
• Ownership in a business entity
• Known stock ownership in prospective business vendors
• Business transactions between the entities
• Transfers of cash or property
• Gifts worth more than $50

Family Relationships: Family relationships include spouses, parents, grandparents, siblings, children, and all in-laws.

Services: Conflicts due to family relationships include work of any nature or services performed in any capacity, whether as part-time staff, full-time staff, independent contractor, consultant, or otherwise.

Document History

Policy Origination Date: May 19, 2023

Who Approved This Policy

Associate Vice President of Human Resources

Contact

Associate Director of Human Resources
Rivers Memorial