Policy

St. Norbert College is committed to maintaining the highest degree of integrity. As such, all employees must avoid any actions or situations that would create a conflict of interest, a potential conflict of interest or the appearance of a conflict of interest between the employee and the college. Employees are expected to perform their duties in good faith and in the best interests of the college. They are also expected to avoid activities, agreements, business investments or interests, and other situations that materially conflict, or appear to conflict, with the interests of the college or interfere with the employee’s duty to loyally serve the college to the best of their ability.

When such conflicts exist, have the potential to exist or may be perceived to exist, they are to be reported to Human Resources immediately. The college will work cooperatively with employees to resolve any situations where such conflicts – real, potential or perceived – may occur.

It’s impossible to provide an exhaustive list of situations that might present a conflict of interest. However, such conflicts are likely to exist, or be perceived to exist, when an employee, relative or close associate of the employee:

• Has an existing or potential financial or other interest that impairs, or might appear to impair, the employee’s judgment when fulfilling college responsibilities.
• Has a significant business relationship with a person or firm engaging in, or seeking to engage in, business with the college.
• Personally profits from any company or organization doing business with, or seeking to do business with, the college.
• Has a significant ownership interest in an outside company or organization that may receive a financial or other benefit from the college’s confidential knowledge or information.
• Has an interest in an organization that competes with the college.
• Conducts business through a separate legal entity (e.g., a corporation or partnership) that lists St. Norbert College as its place of business.
• Accepts compensation or gifts from third parties, such as vendors or college-affiliated groups or individuals. (Modest gifts, such as holiday gift packages meant to be shared with an entire work group and occasional business-related meals, are permitted under this policy.)

Employees who work for another organization, or who run a personal business that may compete with the college or hinder their ability to meet their college responsibilities, may also have a conflict of interest.

Definitions
Conflict of Interest
A situation in which financial or other personal or professional considerations compromise your objectivity, professional judgment, professional integrity and/or ability to perform your college duties.

Potential Conflict of Interest
Circumstances that could lead to a situation that compromises your objectivity, professional judgment, professional integrity and/or ability to perform your college duties.

Perceived Conflict of Interest
A situation where an independent observer might reasonably question whether your actions can be influenced by financial or other personal gain.

Close Associate
A colleague or other individual with whom you have a relationship similar in loyalty or importance to that of a family member.

Financial Interest
Anything of value, including salary or other payments (e.g., consulting fees or honoraria); forbearance or forgiveness of debt; gifts over $75; equity interests (e.g., stock options or other ownership interests); intellectual property rights (e.g., patents, copyrights, trademarks, trade secrets and royalties from such rights); and any other similar interest you or a relative or close relation may have in an entity outside the college.

You have a financial interest if, through a direct or indirect business, investment or family relationship, you have:

• An ownership or investment interest in any entity with which the college has a transaction or affiliation
• A compensation arrangement with any entity with which the college has a transaction or affiliation
• A potential ownership or investment interest in, or compensation arrangement with, any individual or entity with which the college is considering or negotiating a transaction or arrangement

Relative
Your spouse, domestic partner, parent, natural or adopted child, grandchild, great-grandchild, sibling, half-sibling, ancestor or the spouse or domestic partner of your child, grandchild, great-grandchild or sibling.

Procedures

Conflicts of Interest Relating to Gifts
If you or an immediate family member receives a personal gift or other favor, and the circumstances raise the issue of a conflict of interest, you must decline the gift, return it or disclose the issue with your supervisor. Your supervisor, in consultation with Human Resources, will determine whether there’s a conflict and will counsel accordingly.

Conflicts of Interest Relating to Business Transactions
You must tell Human Resources about any arrangement, agreement, purchase, sale or other transaction between you or your immediate family and the college when a direct personal interest is involved.

Conflicts of Interest Due to Outside Employment
You must inform your supervisor about any outside employment (including self-employment) or other work, compensated or not, that may result in, or appear to involve, a conflict of interest.
Your supervisor and the appropriate divisional vice president, in consultation with Human Resources, will evaluate the situation. The college may prohibit outside or self-employment if it would:

• Adversely affect your job performance and ability to fulfill your responsibilities to the college.
• Compete with, conflict with or compromise the college's mission and interests. If any potential conflict arises, the interest and reputation of the college will be considered first and foremost.
• Impair your objectivity and independent judgment in exercising your college duties.
• Conflict with your normal college schedule, duties or responsibilities.