Purpose:

To set forth the policy and procedures of Platt College (the "College") regarding conflicts of interest as they apply to all employees of the College. The policy and procedures set forth here are subject to modification from time to time as the College determines appropriate.

Revision Responsibility: President

Responsible Executive Office: President

Revised: August 3, 2009

Policy:

A. Defining Conflict of Interest

Generally, a conflict of interest occurs when an employee either (1) has an existing or potential financial or other interest which impairs, or might appear to impair, the employee's independent judgment in the discharge of responsibilities to the College or (2) may receive a material financial or other benefit from knowledge or information confidential to the College.

An employee shall be considered as having a personal interest, not only if he/she has a direct personal interest, but also if there will be benefit to a member of his/her family (by which is meant the employee's spouse or domestic partner and dependent children) or to any business enterprise in which the employee has a substantial interest or to any business enterprise in which any member of his/her family has a substantial interest or to any business enterprise in which he/she or a family member serves as a director, trustee or officer.

A conflict of interest arises from the situation, rather than from the character, or even the actions, of the individual. Thus, when an employee has a financial interest at variance with his/her duty to the College, a conflict of interest will exist, even if the employee acts without regard to his/her financial interest.

Employees should conduct their affairs so as to avoid or minimize conflicts of interest and must respond appropriately when a conflict of interest arise. Any employee who has a question as to whether a situation will give rise to a conflict of interest is urged to discuss the matter promptly with the College President and/or his designee.

B. Required Disclosures

All conflicts of interest must be disclosed to the College President.  Moreover, common sense must prevail in the interpretation of the disclosure requirements of this policy. That is, if a reasonable person could be expected to question a relationship or financial interest, it should be disclosed and approval sought.

Without limiting the generality of the foregoing, the following applies to conflicts of interest related to any project sponsored by a governmental agency or other third party.

Initial Disclosures in Connection with Sponsored Projects

Prior to the College entering into any sponsored project proposal in which any employee who is an intended investigator on the project, or any member of his/her family, has a significant financial interest (such as but not limited to salary or other payment for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interest); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).

The employee must disclose both existing and pending relationships with any of the foregoing entities, the relationship of the proposed College project or other activity to that entity and the means by which the employee will ensure separation of his or her role in the project from the role or interest of the employee (or his/her family member) in the entity.

Textbook Policy

When selecting textbooks or materials for courses, it is imperative that faculty members avoid an appearance of a conflict of interest in assigning textbooks or instructional material in the faculty member’s classes from which the faculty member may benefit financially. 

Textbooks and other teaching materials should be selected from their academic and pedagogical merit.  Textbooks authored by faculty members may be used in the classroom provided the appropriate curriculum committee selects the text based on academic needs and not financial needs of the author.  Refer to Policy 02:13:00 Textbooks/Instructional Materials and Conflict of Interest. 

Review of Disclosures

The College President is designated by the College to review all disclosures under this policy. In this capacity, they will determine whether a conflict of interest exists and determine what conditions or restrictions, if any, should be imposed to reduce or eliminate such conflict of interest.

In appropriate circumstances, a conflict, or potential conflict, of interest may be referred to an outside entity for management.

C. Enforcement of this Policy

A violation of any provision of this policy may subject an employee to sanctions, up to and including termination of employment.