4.7 - Conflict of Interest Policy

: Human Resources
: President
: 09/20/2018
: 09/20/2018
: 09/20/2019
Comment on Policy

4.7.1 - AUDIENCE

All University employees.  Faculty are also reminded that they are responsible for adhering to the faculty specific Conflict of Interest Policy in the Faculty Policy Manual.


The purpose of this Policy is to establish a standard of conduct to protect the financial well-being, reputation, and legal obligations of the University, as well as establish a method to protect the University community from questionable circumstances that might arise and to resolve any apparent or real conflicts of interests.


Conflict of Interest: any circumstance in which the personal, professional, financial, or other interest of an employee may potentially or actually diverge from, or may be reasonably perceived as potentially or actually diverging from, his or her obligations to the University and the interests of the University. It includes indirect conflicts, such as benefits provided to a Relative of an employee.

Relative: is considered as:  husband, wife, mother, father, mother-in-law, father-in-law, son, daughter, brother, sister, brother-in-law, sister-in-law, son-in-law, daughter-in-law, uncle, aunt, niece and nephew, first cousin, grandparent, granddaughter, and grandson.  In addition, the definition includes any other related person or non-related person who is part of the employee’s household, or someone whose relationship with the employee is similar to that of a relationship described herein.

4.7.4 - THE POLICY

The underlying principle in this Policy is that employees should avoid any activity, investment or interest that might reflect unfavorably upon their integrity or good name or that of Thomas More University. 

All University employees are obligated to place the University's interest in any business transaction ahead of any personal interest and to disclose the facts in any situation where a conflict of interest may appear.

Potential conflicts usually are resolved by each employee's good judgment.  The following list, not meant to be exhaustive, represents areas where conflicts can arise:

  1. The employee has a personal, financial, professional, or other interest which could affect business judgment;
  2. The employee gains personal enrichment through access to confidential information or data;
  3. The employee accepts outside employment that adversely affects work performance for the University;
  4. The employee has a direct or indirect personal or financial interest in any supplier, partner, or competitor of the University; and
  5. The employee accepts gifts of more than nominal value (e.g., any amount higher than $500 per fiscal year in the aggregate) from any individual or business who does business, or seeks to do business, with Thomas More University.

The University reserves the right to determine when an activity conflicts with the University's interests and to take whatever action is necessary to resolve the conflict.

Faculty must also be cognizant of unique Conflict of Interest which may arise in the academic setting as set forth in the Conflict of Interest Policy – Faculty Specific Activities in the Faculty Policy Manual.

Failure to disclose an actual or apparent Conflict of Interest and/or obtain prior written approval may have serious consequences up to and including termination of employment.


Business Ethics and Conduct Policy
Conflict of Interest Policy – Faculty Specific Activities (see Faculty Policy Manual)
Whistleblower Policy


Employees have a duty to disclose on an ongoing basis any current, proposed, or pending situations that may constitute a Conflict of Interest, as well as all material facts relating to any Conflict of Interest as soon as the existence of a possible conflict of interest is known to his or her supervisor.  Prior to approving an actual conflict of interest, the supervisor must consult with the applicable area vice president or Provost.  In the alternative, the reporting procedures set forth in the University’s Whistleblower Policy may be utilized.


4.7.8 - HISTORY

This is a new policy, replacing language in the Staff Manual (May 2014).

4.7.9 - APPENDIX

There are no appendices to this Policy.

4.7.10 - APPROVALS

Laura Custer, Director of Human Resources

Rob Munson, Chief Financial Officer

Dr. Kathleen Jagger, Acting President