Conflict of Interest Policy and Guidelines for Employees
Description: Establishes policy governing employee conflict of interest matters.
Notes: Approved by Governance and Human Resources Committee 2009/04/13; Approved by the Board 2009/04/27.
Approval Authority: Board of Governors
Signature: "Marshall Cohen"
A conflict of interest exists when there is a divergence between an employee’s personal interests and his or her professional obligations to the University as an employee.
Employees shall seek to avoid conflict of interest situations.
Employees shall make full, timely and ongoing disclosure of a conflict of interest or a potential conflict of interest in accordance with procedures established from time to time.
The University may determine that the activity which constitutes the conflict of interest will be permitted, and may impose such terms and conditions as it determines are appropriate.
Appropriate procedures for the disclosure of conflicts and potential conflicts will be created or negotiated as is appropriate in respect to each category of university employee.
GUIDELINES ON CONFLICTS OF INTEREST
The following guidelines set out the expectations concerning conflicts of interest.
Relevant University policies and reports set out herein are incorporated by reference.
B. Conflict of Interest
1. A conflict of interest depends on the situation, and not on the character or actions of the employee.
2. The standard that will be applied to determine whether a conflict of interest exists is that of an independent observer who might reasonably question whether the employee’s actions or decisions are determined by considerations of, or result in, personal gain, financial or otherwise, or benefit to related persons.
3. The existence of an actual or potential conflict of interest does not preclude the involvement of the employee in the situation where the conflict has arisen or may arise, but it does mean that the conflict must be disclosed and resolved in conjunction with the person to whom the employee reports or to that person or persons set out in procedures promulgated pursuant to this policy or guideline.
4. The following examples, while not comprehensive, are illustrative of situations which may lead to a conflict of interest and which should be disclosed. The situations pertain to an employee and all of his or her non arm’s length relationships, including but not limited to that of a spouse or spousal equivalent, parent, child or sibling, or a person with whom there exists, or has existed, a close personal relationship.
I. Using University Position for Personal Gain
· Entering into a research, business or other contract/transaction on behalf of the University with a company or firm in which the employee or related persons, have a financial interest.
· Influencing the purchase of equipment, materials or services for the University from a company or firm in which the employee or related persons, have a financial interest.
· Assigning reading material or other teaching material to students, when the assignment will result in financial gain for the assigning faculty member, either through royalties or a financial interest in the company publishing the materials under consideration.
· Accepting gifts, benefits or favours from individuals or firms with which the University does business, except as token courtesies.
II. Inappropriate Use of University Personnel, Resources or Facilities
· Directing students or employees of the University to carry out work for a company or firm in which the employee or member, or related persons, have a financial interest.
· Use of University property, resources or facilities for the employee’s personal benefit or the benefit of related persons.
III. Inappropriate Involvement in Hiring or Evaluation
· Participating in or influencing the appointment, hiring, promotion or evaluation of a related person.
· Supervising or evaluating a student who is a related person.
5. Examples of relevant University policies, and reports: