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Conflict of Interest for Employees

Approved By: Vice President for Finance and Administration / Treasurer
History:
Issued - 2005
Revised - January 8, 2013
Responsible Office: Human Resources
Related Policies: Conflicts of Interest and Transactions With Interested Persons Policy; Statement of Ethical Principles
Additional References:

Introduction

Policy Statement
All employees should attempt to avoid personal transactions or situations in which their personal interests will, or appear to, conflict with those of the University.

Applicability
This policy applies to all employees of Washington and Lee University.


Definitions

Conflict of Interest- occurs where the prospect of direct or indirect personal gain for an employee or a member of his/her family could influence the employee's judgment or action in the conduct of university business.

 

Policy

All employees should attempt to avoid personal transactions or situations in which their personal interests will conflict with, or appear to conflict with, those of the University.

Simply stated, a conflict of interest occurs where the prospect of direct or indirect personal gain for an employee or a member of his/her family could influence the employee's judgment or action in the conduct of University business. Employees must inform their supervisors and the relevant dean or vice president of any potential conflict of interest. In certain cases as noted below, an employee must receive written approval from the Vice President for Finance and Administration / Treasurer or General Counsel to enter into certain contracts or business arrangements that could present a conflict of interest.

The types of conflicts of interests that should be reported or disclosed include, but are not limited to, the following:

• Use of University employees, facilities, equipment or services for personal gain or profit without full disclosure, reimbursement of cost, payment of a rental fee, etc;

• Acceptance of consulting fees, honoraria or part-time employment in conflict with professional responsibilities to the University, particularly where proprietary practices or information may be involved;

• Contracting with University employees to perform work for the University that is the same or similar to that performed by the employees during normal working hours. Work should be completed within normal working hours or on an overtime basis. In cases where workload, staffing levels or available expertise requires hiring a W&L employee, then the hiring department should develop a standard wage for this work, ensure the assignments are equally available to those interested and capable of performing the work, and develop a simple letter agreement with the employee. These arrangements will be reviewed by the executive director of Human Resources.

• Contracting or doing business with a University employee or his/her spouse or close relative without prior written approval from the Vice President for Finance and Administration / Treasurer or General Counsel. If such a contractual or business relationship is necessary, the contracting department must explain the need to contract for these services and should submit at least two additional written bids for similar work. Any business relationship with a close relative that pre-dates this revised handbook must be disclosed and submitted for review and approval.

The following activities are prohibited:

• Using privileged information, revealing confidential data, or divulging proprietary information to outsiders for purposes of personal gain or for other than University purposes; and

• Using the name of the University for monetary profit or acting as a private person in a way that could create the impression that an employee is speaking for the University unless the employee's position requires him/her to speak for the University.

The following activities are normally prohibited, with exceptions only upon prior approval of the Vice President for Finance and Administration / Treasurer or the General Counsel:

• Accepting, directly or indirectly, payments, loans, services, entertainment and travel, or gifts of any more than a nominal value from any individual or from any business concern doing or seeking to do business with the University.

If payments, loans, services, entertainment, travel, or gifts of any more than nominal value are received (directly or indirectly) by a University employee, he or she must disclose that fact to the Vice President for Finance and Administration / Treasurer or the General Counsel. In such instances, the goods or services received may need to be returned/rescinded.

Revision History

January 8, 2013 -- Revised to clarify process for seeking an exception to normally-prohibited activities and to clarify disclosure obligations.