Policy 05:21:00

Purpose:

To define what constitutes an employment conflict of interest, and to address specific guidelines, procedures, and sanctions in regard to outside employment and business relationships

Revision Responsibility: President

Responsible Executive Office: President

Created: September 4, 2012

Policy:

Platt College encourages full-time faculty and staff to participate in professional and business activities that enhance their reputations and reflect favorably upon the College. Full-time faculty and staff may not be engaged in any activities, paid or unpaid, that conflict with or delay their services to the College. Full time faculty and staff are required to report, in writing to the appropriate immediate supervisor, any commitment of time to extramural professional business activities, whether current or anticipated, in accordance with College policy.

In such instances, the immediate supervisor shall forward the report to the President. Consulting arrangements between a faculty member/staff member and outside entities having sponsored projects within that employee's department are governed by departmental policy and College policy. Within one week of the beginning of classes each quarter, each full-time faculty or staff member shall provide their immediate supervisor documentation detailing the nature of any current or anticipated outside employment, including consulting, and the amount of time allocated to those activities. 

Conflict of Interest and Reporting Procedure:

Full and Part-time faculty and staff at Platt College have the duty to avoid activities that may result in a conflict of interest or the appearance of a conflict of interest. Faculty and staff shall report any potential or real conflict of interest involving significant ownership in an entity which might compete with the College, or any business interest of the employee or immediate family member in an entity providing goods or services to the College as provided below. A full disclosure by faculty and staff of any such interests shall be reported to the employee's immediate supervisor who will in turn report to the President.

While the College does not want to exclude any entity from providing it with quality goods and services, disclosure is required for interests by faculty or staff members or his or her immediate family as follows:

All full-time faculty and staff must report the existence of a potential or real conflict of interest prior to the commitment of funds. If a potential or real conflict exists, it must be reported to the President on the attached Disclosure Report.

Potential or real conflicts of interest that must be reported which include but are not limited to:

Full-Time Faculty (section a):

a.) Participation in any paid educational activity for another educational institution that offers programs that are in competition with the College. This includes, but is not limited to, a prelicensure track BSN program and a post licensure track (RN-BSN program). Participation in any paid educational activities for another educational institution that offers similar programs will be considered on a case-by-case basis when that participation does not appear to be in direct conflict but in potential conflict due solely to the fact that the program is in the same profession (i.e. teaching in a Master's or Doctoral program). However, this activity must be reported each quarter as outlined in the guideline statement above.

Full-Time Faculty and Full-Time Staff (section b-d):

b.) Significant ownership in an entity providing services, supplies, or equipment to the College in an amount greater than $2,500 in a fiscal year.

c.) Immediate family or business partner who is employed in companies used by the College and who stands to benefit directly from the purchases (i.e. sales representative, service, employee, significant owner, etc.).

d.) Receipt of consulting fees, salary, or other items of monetary value from an entity seeking to or doing business with the College in amounts exceeding $250 per occurrence or $500 per fiscal year.

Each purchaser with a potential or real conflict is required to submit a Disclosure Report form to the Vice President of Academic Affairs stating the nature of the conflict. The report will detail the potential or real conflict of interest and will explain how the conflict will be managed, reduced, or eliminated.

Definitions of Terms:

Significant ownership - Defined as the lesser of 5% ownership or $10,000.

Immediate Family - Defined as descendants, parents, aunts, uncles, brothers, sisters, wards or domestic partners of the faculty or staff member or his/her spouse.

Sanctions and Penalties:

Sanctions and penalties for those who knowingly and willfully disregard this policy, or refuse to comply with its terms, will be determined by the College President. Sanctions include, but are not limited to:

• Letter of reprimand
• Notification to professional societies, funding agencies, or professional journals
• Reassignment of duties
• Adjustment of salary
• Suspension
• Dismissal