Conflicts of Interest
In connection with federal regulation 24 CFR 84 (Institutions of Higher Education, non-profit organizations), Donnelly College has developed the following addendum to the Code of Conduct that prohibits real and apparent conflicts of interest. These may arise among officers, employees, or agents. This policy prohibits the solicitation and acceptance of gifts or gratuities for personal benefit more than minimal value.
A conflict of interest exists when an employee takes work-related action because it benefits him/her personally. Biased decision-making may constitute corrupt conduct.
As an example, no employee, officer, or agent shall participate in the selection, award, or administration of a contract supported by Federal funds if a real or apparent conflict of interest is involved. Such a conflict would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in the firm selected for an award.
The officers, employees, and agents of Donnelly College shall neither solicit nor accept gratuities, favors, or anything of monetary value from contractors, or parties to sub- agreements. However, the College may set standards for situations in which the financial interest is not substantial, or the gift is an unsolicited item of nominal value. The standards of conduct shall provide for disciplinary actions to be applied for violations of such standards by officers, employees, or agents of the College.
An individual employee may often be the only person aware of the potential for conflict. It is therefore his/her responsibility to avoid any financial or other interest that could compromise the impartial performance of their duties and disclose any potential or actual conflicts of interest to their supervisor or other senior staff member. If employees are uncertain whether a conflict exists, they should discuss the related matter with their supervisor and attempt to resolve any conflicts of interest that may exist.
To resolve any conflicts of interest that occur, or could occur, a range of options is available depending on the conflict's significance. These options include:
a) Documenting the details of the disclosure while taking no further action because the potential for conflict is minimal or can be eliminated by disclosure, or effective supervision.
b) Relinquishing personal interest.
c) Being removed from the task/activity/situation where conflict could occur.
d) Disputes over alleged conflicts of interest may be resolved through an appeal through the President’s Office.
Acceptance of gifts or benefits
a) Employees should not accept a gift or benefit that is intended to, or is likely to, cause them to give preferential consideration in the course of their duties.
b) Employees should report to their immediate supervisor if they believe they have received or been offered a favor or benefit.
c) Employees dealing with, or having access to, sensitive investigations, or sensitive commercial information, should be particularly alert to inappropriate attempts to influence them.
The above limitations on gifts do not apply to wedding gifts and gifts exchanged between individuals on birthdays, holidays, and other similar occasions, provided that the gifts exchanged are not disproportionate in value.