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Conflict of Interest

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POLICY

The Conflict of Interest Policy describes the responsibility of all members of the university community to conduct the fiscal business of the university with integrity, and in compliance with all applicable laws and regulations. Members of the university community are expected to maintain the highest ethical standards in the conduct of university affairs.

PURPOSE

The consistent conduct of university business in an honest and ethical manner is vitally important to maintaining public trust and confidence in the university and its employees and representatives. Thus, members of the Board of Trustees and Administrative Officers, faculty and staff shall at all times act in a manner consistent with their fiduciary responsibilities to the university and shall exercise particular care that no detriment to the university results from conflicts between their interests and those of the university. This policy is to assure that conflicts of interest which occur are appropriately disclosed and resolved.

FORMS/RELATED POLICIES

HR 202 Employment of Relatives
Faculty Handbook
Conflict of Interest Disclosure Form

PROCEDURES AND REGULATIONS

University trustees, officers, faculty and staff are expected to avoid even the appearance of impropriety when performing their duties, and must not use their positions or knowledge gained at the University to improperly influence decisions for their personal advantage or for the advantage of their families or friends.

No member of the university may expend university funds for personal gain.

1.  
   1. Disclosure

      University trustees, officers, faculty and staff are expected to disclose to the appropriate university official as specified below any actual or potential conflicts of interest and should not initiate any contract or transaction to which the university is a party until approval is received.

      When any interest on the part of a trustee, officer, faculty or staff member of the university or a member of his/her family poses a possible conflict with the trustee’s, officer’s faculty’s or staff’s university responsibilities, the trustee, officer, faculty or staff member shall promptly report the conflict to the attention of the other trustees or the officers of the university who are participating in or voting on the matter which poses the possible conflict, and that person shall abstain from participation on or voting on such matters.

   2. Procurement

      An employee may not purchase or influence the purchase of goods or services for university use from a firm or organization if the employee or his/her family would receive financial gain, without disclosing such interest in writing to his/her immediate supervisor and to the Vice President for Finance.

   3. Conditions of Possible Conflict of Interest

      No individual within the scope of this policy shall participate in a transaction or procurement when the individual is employed by the outside party; has a pecuniary interest in the outside party; or is negotiating or has an arrangement concerning prospective employment with the outside party.

   4. Solicitation and Acceptance of Gifts, Travel, etc.

      Members of the university must consult with and report to their superiors any instances of gifts or gratuities valued over $25.00 offered to them by any outside organization or any attempt to influence the performance of their assigned duties through the offer of gifts, gratuities or excessive entertainment.

   5. Conflict of Interest Statement

      Each Trustee and Executive Staff member shall sign the attached Conflict of Interest Disclosure Statement annually disclosing any potential conflict of interest and certifying that he or she has read this policy and agrees to abide by it. With respect to Executive Staff, the submission of such signed statement will constitute a condition of continued employment. Such statements shall be maintained with the official minutes of the Board.

      Additionally, all regular full and part time employees, and full and pro rata faculty are required to sign the Code of Ethics/Conflict of Interest form certifying that he or she has read the policy and agrees to abide by it. Certification is required on an annual basis and constitutes a condition of continued employment.

   6. State Law

      This policy is in addition to any obligations imposed on a Trustee or Administrative Officer by the laws of the State of Illinois.

2. The minutes of the meeting shall reflect that a disclosure was made and that the trustee or officer abstained from any participation in the matter. Each trustee and officer shall annually disclose to the university any potential conflicts of interest by signing and submitting a university Conflict of Interest Disclosure Statement to the Secretary of the Board of Trustees.

   Any disclosure of a conflict of interest by a University Trustee or Officer shall be reviewed by the Finance Committee of the Board of Trustees.

   It is the responsibility of any employee to report to the Vice President for Finance any potential conflict of interest of which he/she becomes aware affecting transactions to which the university is a party. The Vice President for Finance will investigate and report the results and findings to the appropriate university officer.

Questions regarding this policy may be directed to Human Resources.