CONFLICT OF INTEREST POLICY

Alfred University

Alfred University, as an institution of higher education, is expected to conduct its business transactions on the same high level and with the same integrity that is expected in its educational approach to students. This conduct of business is carried on through officers, faculty, and staff of the University and encompasses contacts with the public as well as with other University personnel.

This policy is directed towards defining situations where a conflict of interest, or an appearance of conflict, is present or could arise and the appropriate response. The examples do not cover all possible scenarios but are intended to raise the level of awareness in our daily business practices.

A conflict of interest is defined as the existence of a situation where an employee's position or authority may be used to influence or make decisions in ways that would lead directly or indirectly to financial or personal gain for that employee or for his or her family; or whose activities would adversely affect the individual from fulfilling the requirements of his/her position.

The potential for or a conflict of interest exists when a University employee or a member of his/her immediate family:

• Has material financial interest (1) in, business relationship with, or significant indebtedness to anyone who does business with the University;
• Accepts payments, loans, services, significant favors, or gifts from anyone who does business with the University (2);
• Is an officer, director, partner, or consultant to any organization that does business with the University;
• Has outside interests which impair his/her independent, unbiased judgment with regard to his/her University function;
• Participates in other outside activities such as teaching, consulting, or politics;
• Holds membership in a professional organization whose objectives are in conflict with the University's interests to the extent that they would adversely affect the individual from fulfilling the requirements of his/her position.

Basic business practice dictates that each employee accept the responsibility for properly carrying out the duties of his/her position at the University, and with these duties, ensure:

• That all revenues generated, and all expenditures for goods and services be recorded and accounted for promptly within the financial accounting system of the institution;
• That all funds be deposited immediately upon receipt;
• That all intellectual property, including computer software and other copyrighted material, be used in a legal and ethical manner;
• That University funds or assets not be appropriated for personal financial gain or unlawful purposes;
• That all privileged information and confidential data received through employment with Alfred University, be treated properly and transmitted only to those persons with a need to know because of their relationship to the University, to be used for University purposes;
• That privileged information gained from institutional contracted research, or employment, or other University functions not be used for personal gain;
• That all dealings with the public or business entities for conduct of University business be conducted in an ethical manner, free from personal or other improper influences.

Annually, Alfred University faculty and staff should review the Conflict of Interest and Business Ethics Policy as it pertains to his/her individual situation. If he/she determines that a conflict of interest situation exists, then a statement specifying the factors involved should be sent to the University President, or person designated by the President, for review and resolution, if appropriate. If a question exists as to whether a situation constitutes a conflict, then the individual should discuss the matter with his/her Dean, Administrative head or the President's designate, as they choose, for directional guidance.(2)

University faculty and staff who serve as principal or co-principal investigators of Federal grants are required to sign off at least annually explaining any possible conflicts which may exist between their situation and the contracts they administer. (See Federal Government Policy Addendum.)

Addendum

Federal Government policy (National Science Foundation/Health and Human Services) requires that the grantee institution must have and enforce a conflict of interest policy, and for any investigator or person employed by the institution who is responsible for the design, conduct or reporting of research activities which are funded by Federal grants, a financial disclosure policy.

Each investigator must disclose to the institution all significant financial interests(3) of the investigator (including those of the investigator's immediate family) that would reasonably appear to be directly and significantly affected by the research or educational activities funded or proposed for funding by government grants.

Financial disclosure must be made at the time of the proposal and, thereafter, on an annual basis, or as new reportable significant financial interests are obtained.

The institution is responsible for collecting and interpreting all financial disclosures and acting on those which present conflicts to eliminate the conflict.

Footnotes

(1) For the purpose of this policy, a material financial interest is defined as a value exceeding $5,000 or representing more than 5% ownership interest for any one business enterprise or entity.

(2) Conflict of interest situations arise from the individual's position and the responsibilities of that position. For instance, a bank mortgage arrangement could constitute a conflict of interest situation for a university's financial administrator where it normally would not for a faculty member.

(3) A significant financial interest of the investigator (including immediate family) in a business enterprise or entity is a value which exceeds $5,000 or represents more than 5% ownership interest for one enterprise or entity doing business with the University. Financial disclosure must include direct salary or other payments for services by the business entity.

CEER is funded in large part by the United States Environmental Protection Agency.

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