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Conflict of Interest Policy for Employees

Last Updated: November 11, 2019

Statement of Policy

Fordham University (the “University”) is committed to maintaining the highest integrity in all that we do. The University requires all employees to avoid any conflict, or appearance of conflict, between their interests and those of the University, and to disclose promptly any actual or potential conflicts.

Purpose

The purpose of this policy is to ensure that the University operates in compliance with applicable and regulatory requirements, and that the reputation, name, and integrity of the University are not compromised. The fundamental principle guiding its implementation is that no employee should have, or appear to have, any personal or financial interests, relationships, or affiliations that conflict with the interests of the University. This policy is intended to educate employees about situations that generate potential Conflicts of Interest; to clarify expectations about disclosing Conflicts of Interest; and to identify means to manage, reduce, or eliminate such Conflicts of Interest. Under federal and state law, trustees, officers, and certain key employees are generally prohibited from entering into Related-Party transactions. Fordham University extends this prohibition to the employees subject to this policy.

Scope

This policy applies to all designated employees of the University except for members of the University who are subject to the Conflicts of Interest Policy for Trustees, Officers, and Key Employees.

Examples of Conflicts of Interest

It is impossible to give an exhaustive list of situations that might present a Conflict of Interest. However, the most common situations that give rise to a Conflict involve an employee or a relative of an employee who:

  • has an existing or potential Financial Interest or other interest which impairs, or might appear to impair, that person's independent, unbiased judgment when performing University responsibilities.
  • has a significant business relationship with a person or firm engaging in, or seeking to engage in, business with the University.
  • has a significant ownership interest in an outside company or organization and may receive a financial or other benefit from knowledge or information confidential to the University.
  • has an interest in an organization that competes with the University.
  • profits personally, e.g., through commissions, stipends, loans, expense reimbursements or other forms of compensation, from any company or organization doing business or seeking to do business with the University.
  • conducts business, or causes business to be conducted, by a separate legal entity (e.g. a corporation or partnership) and lists a Fordham location as its place of business.
  • accepts compensation or gifts from third parties, such as vendors, or other University-affiliated groups or individuals.

Gifts, Gratuities, and Favors

Employees may not solicit or accept, either directly or indirectly, any gift, gratuity, or favor with an economic value in excess of $50, or any gift, gratuity, or favor that may be reasonably perceived by an impartial observer to affect the employee’s decision-making authority.

Subject to any other applicable rules or regulations, this policy is not intended to prohibit the acceptance of modest insubstantial courtesies, openly given and acknowledged as part of the usual business amenities (e.g., occasional business-related meals, holiday baskets, or promotional items) of nominal or minor value not to exceed $50 (cumulative value for courtesies, meals, and/or items not to exceed $250 in any twelve-month period).

Failure to abide by the provisions of this section may result in disciplinary action, up to and including, employment discharge.

Disclosing Conflicts of Interests

It is the responsibility of the employee to report promptly any actual or potential conflict that may exist between him/her (and/or his/her relative) and the University to the Office of Internal Audit. Failure to disclose any existing or potential Conflict of Interest may result in disciplinary action, up to and including employment discharge.

Annual Reporting Requirements

Employees subject to this policy are required to submit a disclosure form annually, which affirms their acceptance of the terms of this policy and the requirement to disclose any existing or potential Conflict as defined below.

Managing Conflicts of Interests and Enforcement

The Fordham University Board of Trustees has delegated authority to the Office of Internal Audit to investigate, manage, resolve, and report all Conflicts of Interest to the appropriate University officer(s) and to the Audit and Risk Management Committee of the Board of Trustees. Once a Conflict of Interest is disclosed to the Office of Internal Audit, in consultation with the Office of Legal Counsel, it will determine the next steps with respect to the Conflict. It may determine that the Conflict of Interest will be managed, reduced, or eliminated. The President of the University, in consultation with the Office of Internal Audit, Office of Legal Counsel, and the Chair of the Executive Committee of the Board of Trustees, retains final authority to determine appropriate disciplinary measures for failure to comply with the terms of this policy.

Policy Definitions

Conflict of Interest: A conflict of interest arises if there is an actual divergence between private interests and the employee’s professional and fiduciary obligations to the University. A potential conflict of interest exists when circumstances may lead to the divergence between private and University interests. A perceived conflict of interest exists when an independent observer might question whether the employee’s actions can reasonably be influenced by considerations of personal gain, financial or otherwise.

Relative: An individual’s spouse, domestic partner, parent, natural or adopted child, grandchild, great-grandchild, sibling, half-sibling, ancestor, or the spouse or domestic partner of the individual’s child, grandchild, great-grandchild, or sibling.

Related-Party Transaction: Any transaction, agreement, or other arrangement in which a related party has a financial interest and in which the University or an affiliate of the University is a participant.

Financial Interest: An employee has a “Financial Interest” if, either directly or indirectly, through a relationship involving business, investment, or relatives, he/she has:

  1. An ownership or investment interest in any entity with which the University has a transaction or affiliation;
  2. A compensation arrangement with any entity with which the University has a transaction or affiliation;
  3. A potential ownership or investment interest in, or compensation arrangement with any individual or entity with which the University is considering or negotiating a transaction or arrangement.