The following policy regarding
potential “conflict of interest”
situations is adopted by Duquesne University
of the Holy Spirit (the “University”)
for the purpose of assuring a high level of
organizational integrity and avoidance of conflicts
of interest on the part of any administrator
or employee.
This policy is intended to assure that the University
will be fully informed with respect to any financial
or other interests which any employee may have
in any person, firm or entity which does business
with the University. The primary principle underlying
this Conflict of Interest Policy is that those
persons employed by or who have a fiduciary
duty to the University must never permit their
personal interests to conflict, or appear to
conflict, with the interests of the University.
A. POLICY
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Any employee
having an existing or potential interest in
a contract or other transaction with a person,
firm or entity which does business with the
University, shall make immediate and complete
disclosure of the interest to the appropriate
Vice President, the Secretary of the University
or the President. The interested party is
required to disclose the nature and extent
of his or her interest and any relevant and
material facts, known to him or her, about
the contract or transaction which might reasonably
be construed to be adverse to or in conflict
with the University’s interest.
-
An employee
shall be deemed to have an “interest”
in a contract or other transaction if the
employee or any member of his or her immediate
family is (i) the party or one of the parties
contracting or dealing with the University;
(ii) an owner, director, officer or key employee
or has a significant financial or influential
interest in the entity contracting or dealing
with the University; or (iii) reasonably likely
to gain a financial or other substantial personal
benefit if the contract or transaction is
approved.
-
Absent full
disclosure and prior written approval of the
President, no employee may serve as a director,
officer, employee or consultant of any business
entity which does business with or is competitive
with the University.
-
No employee
or any member of his or her immediate family
may accept a gift, directly or indirectly,
in any form, from any business entity which
does business with or desires to do business
with the University, a supplier or prospective
supplier of the University. For the purpose
of this policy, the term “gift”
means anything with a value in excess of $150.00,
including entertainment, which does not facilitate
the discussion of the University’s business
or otherwise serve a demonstrable business
purpose. In addition, an employee may not
utilize the services of any person employed
by the University nor any account, sales tax
exemption, material, equipment, machinery
or property of the University for personal
use without written consent of the President.
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In the event
that an employee has any doubt concerning
the propriety of accepting any gift or services
or the applicability of the reporting, and
prior approval procedures, the University
General Counsel should be consulted for guidance.
B. ANNUAL DISCLOSURE
On or about December 1st of each year, and such
other times as the President or the Chairman
of the Board of Directors shall request, each
designated employee shall deliver to the Secretary
of the University, a written statement in the
form attached hereto, in which each such employee
shall disclose potential conflicts of interest
as set for in this Policy.
All employees are expected to act fairly and
honestly in all transactions with the University
and with others to maintain the high ethical
standards of the University. If a situation
arises where an employee is unsure whether there
may be a violation of this Policy, he or she
should contact the General Counsel for guidance.
Discovery of events of a questionable, fraudulent
or illegal nature, or which appear to be in
violation of this Policy must be reported promptly
to the President. Violations of this Conflict
of Interest Policy may constitute grounds for
disciplinary action.
11/6/08
