Appendix 5 Conflict of Interest
While it is useful to provide basic guidelines to assist employees in assessing potential conflict situations, no list can be so exhaustive as to provide direction for all the variable circumstances which may arise. The personal good judgment of employees is indispensable.
The University remains committed to academic freedom and nothing in this policy should be construed as diminishing this commitment.
- SCOPE
This policy applies to all Gonzaga personnel.
- DEFINITION
A conflict of interest is considered to exist if an employee's actions or activities on behalf of the University result in preferential treatment or an improper gain or advantage to the employee, the individual's family or business associates, or conversely, has a detrimental effect on the University's interests. It can include an instance in which an employee fails to exercise due care, skill, and judgment on behalf of the University in the performance of the individual's duties because of a conflict of interest.
- GUIDELINES
- All employees have a duty to act in the best interests of the University. Therefore, all employees have a duty to avoid conflicts of interest and to conduct themselves in a manner which will maintain the integrity and accountability of Gonzaga University.
- Employees who have a financial or family interest in a business which furnishes goods or services, or contracts with the University, should not undertake to act for the University or enter into negotiations or contracts with that business, either directly or indirectly, on behalf of Gonzaga University. No employee may participate in the selection, award or administration of a contract with any party with whom he or she is negotiating potential employment, or has any arrangement concerning potential employment.
- Employees must avoid outside employment or business activity which may conflict, or appear to conflict with University interests. Directorships or consultation agreements for which the employee is compensated must be approved in writing by the appropriate dean or area vice president.
- Employees must provide full written disclosure of any business, financial enterprise or activity which might influence, or appear to influence, decisions or actions concerning University matters. Disclosure should be made by completing a disclosure statement annually or whenever a significant change in interest occurs. The disclosure statement will be maintained in a confidential file by the appropriate dean or area vice president.
If an employee anticipates a conflict of interest or the appearance of a conflict may arise, he or she should seek advice from the appropriate dean or vice president. Employees should not participate in any way in the matter that is the subject of their concern until it has been resolved by the dean or vice president. Such determination will be in writing.
- Employees should not use confidential information or special knowledge acquired as a result of their relationship with the University to, among other things, purchase or sell securities, real property or other goods or services, or to in any way enhance their own personal financial well being by using such inside information to their own advantage.
- Employees may use the name of the University to identify themselves professionally, but unless they are authorized to do so, they should be careful not to represent themselves as speaking on behalf of Gonzaga University.
- Employees may not use students or other employees of the University to perform personal services for themselves or others if improper gain or benefit would result.
- Employees must not disclose information regarding the University's intentions as to investments, property development, sale or acquisition of property, or the University's purchasing and contracting activities.
- Employees must not make unauthorized use of University equipment, property or other resources for personal benefit or for the personal benefit of any other person.
- Personal gifts or favors from persons with whom the University has a business relationship should be discouraged. To avoid improper influence, or the appearance or suggestion of such, personal gifts of more than nominal value should not be accepted. Special caution has to be exercised by employees involved in awarding or administering federal or government contracts as it is a crime to solicit or accept gratuities, favors or anything of value from contractors or potential contractors.
- Employees may not be involved in University matters pertaining to a member of his or her immediate family, insofar as said matter affects such family member's employment, evaluation or advancement at the University, without first making a full disclosure. Such disclosure must be in writing and shall include the nature of the relationship and the impact or potential impact the employee's actions may have on such family member. The disclosure should be made prior to any action being taken with regard to the family member and should be made to the appropriate dean or vice president. (See also University policy statements concerning amorous relationships and nepotism.)
- All employees have a duty to act in the best interests of the University. Therefore, all employees have a duty to avoid conflicts of interest and to conduct themselves in a manner which will maintain the integrity and accountability of Gonzaga University.
