Employee Conflict of Interest and Commitment

1.0    Purpose

This policy establishes guidelines for determining, disclosing, and acting on actual, potential, or perceived conflict of interests and setting expectations of commitment.

2.0    Revision History

3.0    Persons Affected

3.1    All regular full-time and regular part-time benefited employees except for the president of the college who is covered under the Conflict of Interest: Board of Trustees and President policy.

4.0    Policy

The policy of Casper College is to ensure the following.

4.1    The college upholds the public trust and operates with integrity.

4.2    The college has a process to identify, assess, and manage potential or perceived conflicts of interests.

4.3    Employees act in the best interest of the college.

4.4    Employees identify and disclose potential conflict of interests and conduct themselves in a manner that preserves the integrity of the college.

5.0    Definitions

5.1    Conflict of Interest. A situation in which an individual is in a position to actually or potentially exploit a professional or official capacity for personal, familial, or business relationship gain, which may be financial or otherwise. A conflict of interest may compromise an individual’s objectivity or judgement.

5.2    Perceived Conflict of Interest. Circumstances are such that a reasonable person might suspect or anticipate a conflict of interest.

5.3    Conflict of Commitment. Personal or non-work related activities that prevents or impedes employees from meeting their commitments of time and energy to the college.

5.4    Family. Spouse/partner, children (including adopted and stepchildren), siblings (whole, half, and adopted), parents, grandparents, grandchildren and in-laws and spouses of all of these family members

5.5    Business Relationship. When an employee or their family members is an employee, officer, director, employee, partner, trustee, or controlling stockholder in an organization that did substantial business with the college the previous year.

5.6    Financial Interest. Anything of value including but not limited to compensation, consulting fees, honorariums, debt forgiveness, gifts or favors over $100 in value, stock, stock options or other ownership, or use of student or staff time where the employee or a family member financially benefits from such use.

5.7    Substantial Business. An organization that received $10,000 or more from the college in the previous year.

5.8    Substantive Financial Interest. When an employee or their family member (1) has direct or indirect has ownership interest of 5% or more in an organization that does substantial business with the college, 2) receives, directly or indirectly, cash or property receipts of $10,000 or more annually from an organization that does substantial business with the college, or 3) received more than $10,000 in compensation, remuneration, and benefits from the college the previous fiscal year.

5.9    Conflict of Interest or Commitment Compliance Form. This form is used identify actual, perceived, or potential conflicts of interest.

5.10    Management Plan. A plan developed to eliminate an actual conflict of interest or commitment or mitigate a potential or perceived conflict of interest. The plan should include the conflict of interest being addressed, restrictions, limitations, or modification placed on the employee, and who is responsible for addressing non-compliance.

6.0    Responsibilities

6.1    Supervisors are responsible for maintaining compliance with this policy.

7.0    Procedures

7.1    Duty to Disclose
Employees must disclose potential conflicts of interest or commitment for themselves or their family members upon hire. Employees must update their disclosure information within 15 business days of discovery of a new potential conflict of interest or commitment.

7.1.1    The Human Resource Department provides all new employees with a copy of the Conflict of Interest or Commitment Compliance form on their first day of employment.  

7.1.2    Administrative and classified staff employees submit a completed Conflict of Interest or Commitment Compliance form to their immediate supervisor within 15 business days. Faculty employees submit a completed Conflict of Interest or Commitment Compliance form to their dean within 15 business days.

7.1.3    The immediate supervisor or dean will determine one of the following findings.

7.1.3.1    No Significant Conflict of Interest or Commitment. The disclosed situation does not meet the threshold of a significant financial interest and there is no suggestion of actual, perceived, or potential conflict of interest; no action is required.

7.1.3.2    Potential or Perceived Conflict of Interest or Commitment. The disclosed situation has the potential or could be perceived as a conflict of interest or commitment. The immediate supervisor or dean submits the form to the next level supervisor. Next level supervisors who also find that a potential or perceived conflict of interest or commitment exist must develop a management plan for the employee.

7.1.3.3    Actual Conflict of Interest or Commitment. The disclosed situation represents an actual conflict of interest or commitment. The immediate supervisor submits the form to the next level supervisor. Next level supervisors who also find that a conflict of interest or commitment exist must develop a management plan for the employee.

7.1.4    Employees may appeal the decision through the grievance process.

7.1.5    The next level supervisor maintains the Conflict of Interest or Commitment forms and the management plans.