The purpose of this policy is to ensure that all members of the University, particularly trustees, advisors, academic staff, and administrative staff understand potential conflicts of interests and conflicts of commitment, and avoid situations where such conflicts occur. 

Scope

This is an institution-wide policy, affecting trustees, advisors, academic staff, administrative staff, and students of the University. 

Referenced Laws, Regulations, and/or Policies 

This is the University policy. 

Compliance/Policy Statement 

All members of the University must avoid any conflict between their personal interests and the institutional interests of the University as well as their personal commitments and their commitments of the University. While this policy is mostly concerned with trustees, advisors, academic staff, and administrative staff, there could also be times when students could potentially engage in such conflicts. They shall avoid any situation where it would be reasonable for an objective observer to believe that the person's judgment or decisions regarding the affairs of the University might be adversely affected because they have personal conflicting interests or commitments. 

Any member of the University, who has a potential conflict of interest or commitment, covered by this policy, must immediately disclose such potential conflict by writing to a superior or announcing it verbally in a group meeting where all those concerned attend, such as Trustees meetings, University Management meetings, and Department meetings. The member may continue to participate in the activity in question only after being approved by the superior or the group. The University values active participation of all members of the University in the it’s affairs. However, even if someone is carrying out an activity with a clean conscience, there are unforeseen circumstances of conflict. It is important for all members of the University to disclose anything that might get them into such conflicts. 

If it is found that any member of the University fails to make such disclosure knowingly, the case will be reviewed and corrected on a case-by-case basis by the University Management or the Board of Trustees, in the University’s spirit of transparency and accountability. Depending on the nature of the case, an investigative committee may be formed by University Management or the Board of Trustees. 

To offer further clarity, the following definitions are provided. 

Interested Persons 

Interested Persons are defined as any Trustee, officer, committee member, staff, substantial contributor or other person in a position to materially influence the decisions of the University, or person with material non-public information relating to actions in which the University might be involved and their respective family members. They owe a duty of loyalty to the University, and this requires that in serving the University they act, not in their personal interests or in the interests of others, but rather solely in the interests of the University. Interested Persons must have an undivided allegiance to the mission of the 5 University and may not use their position as Interested Persons, information they have about the University, or the University’s property, in a manner that allows them to secure a pecuniary or other material benefit for themselves or their relatives, friends or employers. Accordingly, no Interested Person may use his or her position at or relationship with the University for personal gain or to benefit another at the expense of the University, its mission, or its reputation. 

Conflict of Interest 

A conflict of interest may arise when a person has an existing or potential financial interest or other material interest that impairs, or might appear to impair, his or her independence or objectivity in the discharge of responsibilities and duties to the University. This Policy is intended to protect the University’s interests when it is contemplating entering into a contract, transaction, or arrangement that might benefit the private interests of an Interested Person. This Policy is also meant to aid Interested 

Persons in performing the duties imposed upon them by the laws of the District of Columbia and the United States of America with respect to their management responsibilities and fiduciary obligations to the University. The University is committed to transparency and openness in its operations. 

Every Interested Person must discharge his or her duties in good faith, with the degree of care that an ordinarily prudent person in such a position would exercise under similar circumstances. This requires using common sense, being diligent and attentive to the University's needs, and making thoughtful decisions in the best interests of the University. No Interested Person may take personal advantage of a business opportunity that is offered to the University unless the Board of Trustees of the University first determines not to pursue such opportunity. 

Each Interested Person must protect the confidential information of the University and must not use confidential information of the University for his or her personal benefit, or use such confidential information or his or her position as an Interested Person to the detriment of the University. Confidential information is information obtained through the Interested Person’s position that has not become public information. 

Conflict of Commitment

A conflict of commitment may occur when any Interested Person’s involvements in their outside commitments interfere with the responsibilities that they are charged within the University. This includes fulfilling academic and administrative duties as well as fulfilling board and advisory duties. 

Financial Interest 

An Interested Person has a financial interest if the person has, directly or indirectly, through business, investment, or family: 

a. An ownership or investment interest in any entity with which the University has or is considering a transaction or arrangement, 

b. A compensation arrangement with the University or with any entity or individual with which the University has or is considering a transaction or arrangement, or 

c. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the University is negotiating a transaction or arrangement. Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial. 

Review

The Board of Trustees is responsible for ensuring compliance with this policy in various offices of the University. 

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