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Policy Index
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.
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| 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: |
- Each staff employee has a duty to act in the best interest
of the University.
- 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.
- 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.
- 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.
- 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.
- 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.
- No staff employee should make unauthorized use of University
resources for his/her personal benefit or for the benefit of
any other person.
- 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.
- 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.
- 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.
- 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.
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| Employees represented by a bargaining unit may be governed by the appropriate bargaining unit agreement. |
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