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Policy 304 - Conflict of Interest

304. Conflict of Interest

Statement

Santa Clara University employees are expected to avoid conflicts of interest, or appearances of conflict.

Procedure

Definition

A conflict of interest is considered to exist in an instance where an individual's actions or activities involve both an advantage to the employee and an adverse effect on the University's interests. It can also result when an individual's association or involvement with a third party prevents the employee from exercising care, skill and prudent judgment on behalf of the University in the performance of assigned duties.

A conflict of interest exists if an employee has an existing or potential interest, financial or non-financial, that may impair (or appear to impair) the individual's independent judgment when performing University responsibilities, or if the employee receives or may receive a material, financial, or other benefit from knowledge of confidential or proprietary University information. In addition, a conflict exists if any of the above circumstances exist involving a member of the immediate family of an employee.

A conflict of interest exists when an employee influences or attempts to influence any University business transaction, research activity or other decision in ways which could lead to any manner or form of personal gain for the employee, other than from salary from the University, regardless of source. The conflict extends also to personal gain for the employee's family members. The University will not knowingly do business with any enterprise owned in whole or in part by any employees or members of their families.

Gifts and Entertainment

No employee may solicit or accept, directly or indirectly, any gift or gratuity that might reasonably be interpreted by others as being of such a nature that it could affect his or her impartiality.

Endorsements

No employee of the University shall authorize for University use any product or service furnished by a firm in which the employee has financial interest that could be enhanced as a result of such recommendation. When requested, employees may provide references on products and services used by the University. The furnishing of such a reference is not to be construed and should not be presented as an official University endorsement but rather a statement of personal opinion or preference.

Requirements

In the event the employee enters or will enter into a situation creating a conflict of interest, advance consultation with the supervisor is required. The employee is to follow the instructions and further recommendations of the University. In cases of uncertainty, employees in advance must consult supervisors for clarification of conflict of interest.

Responsibility

All University employees must follow the guidelines outlined in this policy. Other University policies may apply to conflicts of interest, such as confidentiality. Please refer to the appropriate policies for additional information.

Resource

Contact Human Resources if you have questions or if you would like more information about this policy.


Policy Approved: October 23, 1998
Last Updated: October 28, 1998

Maintainer: Human Resources

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