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THE UNIVERSITY OF CHICAGO
PERSONNEL POLICY GUIDELINES

Subject: Conflict of Interest Policy

Section: U600

Date: May 17, 2004

Prior Version Date(s): October 15, 1986; October 31, 1985


Purpose: Staff employees are obligated to avoid involvement in activities which might conflict, or might appear to conflict, with their institutional responsibilities. Decision-making in matters in which a conflict of interest may exist, may not only create an appearance of impropriety, but may, particularly where government funds are involved, violate the law.

The University publishes basic guidelines to which staff can refer, but the University is also mindful that the good judgment of its staff is essential and that no list of rules or guidelines can provide direction for all the varied circumstances that may arise.

Policy: This policy addresses potential conflicts of interest and conflicts of commitment which might arise in the course of a staff employee’s duties and activities outside of the University. Staff employees who engage in business or professional activities outside the University should ensure that these activities do not interfere with their obligations to the University. Staff employees should neither profit nor gain any advantage from any endeavor which may come, nor reasonably appear to come, at the expense or well-being of the University or its reputation.

Guidelines:

  1. Each staff employee has a duty to act in the best interest of the University.
  2. A staff employee who has directly or through family or business connections, an interest in suppliers of goods or services, or an interest in contractors or potential contractors with the University, should not act on behalf of the University in any transaction involving that interest. No staff employee should participate in the selection, award, or administration of a contract with any party with whom he/she is negotiating regarding potential employment or any arrangement concerning potential employment.
  3. A staff employee should avoid outside employment or business activity involving obligations which may in any way conflict or appear to conflict with the University's interests, including its interest in the full- or part-time services of any staff member. Directorships or consultation arrangements for which a staff employee will receive compensation must be cleared with the immediate supervisor or department head, or with the appropriate vice president of the University.
  4. To avoid the appearance of a conflict of interest, a staff employee should provide full disclosure of any business or financial enterprise or activity in which he/she is involved which might influence, or might appear to have the capacity to influence, his/her official decisions or actions on University matters. Disclosure should be in writing tendered to the immediate supervisor, department head or, in the case of supervisory personnel and department heads, to the appropriate vice president of the University.
  5. A staff employee should refrain from personal activities that include, but are not limited to, the purchase or sale of securities, real property, or other goods or services in which he/she could use or might appear to have the opportunity to use, for personal gain, confidential information or special knowledge gained as a result of his/her relationship with the University.
  6. A staff employee should refrain from unauthorized disclosure of non-public information concerning the University's intentions, its investments, its property development, sale or acquisition, its purchasing or its contracting activities.
  7. No staff employee should make unauthorized use of University resources for his/her personal benefit or for the benefit of any other person.
  8. It is sound practice to discourage personal gifts and favors from people with whom the University has a business relationship. Personal gifts of more than nominal value should be tactfully declined or returned to avoid any appearance or suggestion of improper influence. Any staff employee involved in awarding or administering contracts using federal or other government funds should keep in mind that he/she is prohibited by law from soliciting or accepting gratuities, favors or anything of monetary value from contractors or potential contractors.
  9. Any staff employee doing business on behalf of the University with specific vendors should refrain from participating on vacation trips with representatives of those vendors. Such trips are not appropriate, even when a staff employee pays a fee to the vendor to participate in such trips.
  10. No staff employee should act in any University matter involving a member of his/her immediate family including, but not limited to, matters affecting family members’ employment or evaluation or advancement in the University, without first making full disclosure in the manner described in paragraph four, above. Such disclosure should include the nature of the familial relationship and the impact or potential impact of the staff employee’s action on such family member.
  11. Any staff employee who believes that his/her conduct or activities may conflict with these guidelines or activities, may appear to conflict with these guidelines or may otherwise create a conflict of interest, should disclosed the details with a responsible University official in the manner described in paragraph four, above.
Employees represented by a bargaining unit may be governed by the appropriate bargaining unit agreement.

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