4.40 Conflict of Interest Policy

I. Policy

The College expects its employees to discharge their duties in the best interest of the College and the public, avoiding conflict of interest.  To that end, no employee shall have any interest, financial or otherwise, direct or indirect, or engage in any business transaction or professional activity, or incur any obligation of any nature that is, as determined by the College, in substantial conflict with the proper discharge of his/her official College responsibilities.  The failure of an employee to comply with this policy shall constitute grounds for immediate termination of employment.

II. Regulations

A. The following conflict of interest standards shall apply to all employees of the College:

1. An employee shall not accept or solicit any gift, favor, service, or other benefit: that could reasonably be construed to influence the employee's discharge of assigned duties and responsibilities, or that could reasonably be construed as being offered with the intent to influence the employee's official conduct; or that has a value in excess of $50.

2. An employee charged with the duty of preparing plans, specifications, or estimates for contracts; awarding or administering contracts; or inspecting or supervising construction shall not solicit or accept any gift, favor, service or benefit, regardless of its value, from any contractor, subcontractor, or supplier who has a contract with the College; who has performed under a contract with the College during the past year; or who anticipates bidding on such a contract in the future.  The preceding sentence is not intended to prevent the acceptance of honorariums for participating in meetings, advertising items, souvenirs of nominal value, or meals furnished at banquets.

3. Section 4.40 shall not prohibit the acceptance of customary gifts or favors from friends and relatives where it is clear that it is the relationship rather than the business of the donor or the position of the employee which is the motivating factor for the gift or favor. However, all such gifts are required to be reported to the President or designee by the employee if the gifts are made by a contractor, subcontractor, or supplier doing business directly or indirectly with the College.

4. An employee shall not accept employment or compensation or engage in any business or professional activity that could or does impair the employee's independence of judgment in the performance of assigned duties and responsibilities, or that could require the disclosure of confidential information acquired by reason of the employee's College position.

5. An employee shall not make an investment or maintain a financial, business, or professional interest that creates a conflict with the proper discharge of assigned duties and responsibilities or otherwise creates a conflict with the best interest of the College. The preceding sentence shall not prohibit the ownership by an employee of five percent or less of the securities of any publicly traded company.

B. An employee who believes that he/she may have a conflict of interest shall disclose the interest in writing to the President. The employee shall have a 90-day period in which he/she is to resolve the conflict to the satisfaction of the President who will ensure that in the resolution the College's and public's best interests are protected.