092.0 Conflicts of Interest for Employees with Executive or Administrative Responsibilities or Receiving Federally Funded Grants

Created by: Dana Trebing on 02/24/2005
Category: 0 - General Administration; 90 - Miscellaneous
 
Originator: Vice President for Finance and Administration
Current File: 092.0
Adoption Date: 06/25/2013
Reviewed for Currency: 06/25/2013
 
Replaces File: 092.0
Date of Origin: 05/31/2004
 
Classification:
 
In Archive? 0


092.0 Conflicts of Interest for Employees with Executive or Administrative Responsibilities or Receiving Federally Funded Grants

 

A. Background

The University recognizes that employees with executive or administrative responsibilities have a duty of loyalty and fidelity in carrying out their responsibilities. This duty means that such individuals must administer the affairs of the University honestly and economically, exercising their best judgment, skill and care on behalf of the University. Additionally, employees receiving federally funded grants must comply with relevant federal regulations regarding conflicts of interest.

 

B. Policy

To assist individuals in meeting these responsibilities, a conflict of interest policy has been developed and implemented.

 

C. Guidelines

1. Applicability of Policy. This conflict of interest policy shall apply to those employees with executive or administrative responsibilities as designated by the President of the University. The members of the Board of Trustees are covered under the by-laws of the University -- Section 9. Additionally, employees receiving federally funded grants must comply with relevant federal regulations regarding conflicts of interest.

2. Duty of Loyalty. Employees of Furman University with executive or administrative responsibilities are required to exercise the utmost good faith in all transactions and matters concerning their duties to the University and its property. In all dealings with and/or on behalf of the University, such individuals will be held to a strict rule of honest and fair dealing. They shall not use their position, nor use or disclose knowledge gained there from, in any way that might give rise to a conflict between the interests of the University and their own. They shall not, at any time, act in a manner that is contrary to the interests of the University.

3. Independent Decision Making. Such individuals may not accept gifts, valued at more than $100; favors; or hospitality that might influence their decision making or actions on behalf of the University.

4. Disclosure of Any Duality of Interest or Possible Conflict of Interests. Prior to consummating a transaction or acting upon a matter involving the possible existence of a duality or conflict of interest, the individual involved shall make a full disclosure of all relevant facts. In the case of the President of the University, such disclosure will be made to the Chairman of the Board of Trustees. The Furman University Questionnaire for Employees with Executive and Administrative Responsibilities Disclosure form shall be provided to the Human Resources Department by other employees with executive or administrative responsibilities. In addition, such individuals shall periodically report in a similar manner all affiliations, whether as an owner, director, officer, partner, management employee, consultant or other significant relationship involving ownership or governance, with any other for-profit or non-profit entity,

(i) from which the University obtains or may be expected to obtain goods or services;

(ii) to which the University provides or may be expected to provide goods or services; or

(iii) which competes or may be expected to compete in any respect with the University.

Any such existing or potential relationship with a subsidiary, joint venture or the like should be disclosed as well. The term "goods or services" includes commercial, industrial, banking and professional services or goods.

5. Grant Recipients. Employees receiving federally funded grants must comply with relevant federal regulations regarding conflicts of interest. See the Office of Grants Administrationís website for the forms that must be completed for compliance.

6. Members of Immediate Family. Furman employees with executive or administrative responsibilities will be asked to report affiliations, positions, and material financial interests (as outlined in Section 4) held by members of their immediate families. Similarly, gifts valued at more than $100, gratuities, or entertainment held or accepted by members of immediate families must be reported. For purposes of this policy, "immediate family" is defined as spouses, domestic partners, parents, siblings, and children.

7. Annual Update. Each such individual shall, at least annually, update the disclosure regarding any such interests.

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