All Policies › Administration & Operations › Conflicts of Interest and Commitment
Conflicts of Interest and Commitment
Responsible Office
University President
Policy Owner
Vice President for Strategic Operations & Human Resources
Policy Contact
Vice President for Strategic Operations & Human Resources
Issued
2019-07-11
Last Revised
2026-10-01
On this page: Policy Statement · Reason for Policy · Policy Scope · Procedures · Frequently Asked Questions · Forms · Appendices · Additional Contacts · Definitions · Responsibilities · Related Information · History
Policy Statement
North Central University community members must avoid any situation, conflict, or appearance of conflict, between their personal interest and the interest of the university in dealing with any organization or individual having, or seeking to have, any business relationship with the university or with any organization or individual whose objectives or interest may be adverse to university interests.
Conflicts of interest occur when university members are in a position to influence a decision on policy or any business decision from which they might directly or indirectly receive financial benefit or financial interest, or give improper advantage to associates. Conflicts of commitment arise when university members’ involvement in outside activities substantially interferes with their primary commitments to the university.
University community members must not use their official university positions or influence to further gain or advancement for themselves, parents, siblings, spouse or partner, children, dependent relatives, or other personal associates at the expense of the university.
Favors of any value should be recognized for their potential to influence the objectivity of the recipient. Employees are prohibited from soliciting or accepting gifts or offers of hospitality when such solicitation or acceptance may influence, or have the appearance of influencing, the performance of university duties.
The university allows and encourages faculty and staff to engage in outside activities and relationships that enhance the mission of the university. All university community members are to act with honesty, integrity, and in the best interest of the university when performing their duties, and to abide by the highest standards of research, educational, professional, and fiscal conduct. Given that the university allows and encourages outside activities and relationships that enhance the mission of the university, potential conflicts of interest and commitment are inevitable.
If an employee has any power of influence to approve or disapprove a transaction proposed to be entered into between the university and that person or between the University and any entity or individual having a significant relationship to that person, the employee has a potential conflict of interest and may not participate in the process leading to the approval or disapproval of the transaction unless the underlying facts giving rise to the potential conflict of interest are disclosed and approval for participation is obtained.
Disclosure
Members of the university community have an obligation to address both the substance and the appearance of conflicts of interest and commitment and, if they arise, to disclose them to the appropriate university representative and withdraw from debate, voting, or other decision-making processes where a conflict of interest exists or might arise. Real, suspected, or potential conflicts of interest or commitment must be immediately disclosed in writing to a superior and to the Office of Human Resources.
All employees must complete a Conflict of Interest Disclosure Form at the time of their hiring, even if they have no reportable external activities, financial interests, or business interests. Key employees must complete a Conflict of Interest Disclosure Form annually.
Investigation and Mitigation
All conflicts of interest or commitment, actual or suspected, must be investigated by the appropriate university official; evaluated; and, if found to be significant, eliminated or managed by an appropriate approved action plan.
Violations and Sanctions
Violations, as determined by the appropriate dean, director, supervisor, or university official, are considered misconduct on the part of a faculty or staff member and may be subject to institutional sanctions up to and including termination of appointment in accordance with applicable disciplinary procedures.
Retaliation
The university prohibits any form of retaliation against any individual because of the individual’s good faith participation in reporting or otherwise expressing opposition to, suspected or alleged misconduct, or participating in any process designed to review or investigate suspected or alleged misconduct or noncompliance with applicable policies, rules, and laws. No employee will be adversely affected because they refused to carry out a directive which constitutes fraud or is a violation of local, state, federal or other applicable laws and regulations.
Individuals who believe that retaliation is occurring or has occurred, as a result of their good faith participation, must report those acts to the appropriate university official.
Disputes and Appeals
When a university community member disputes any action or decision related to a potential conflict of interest or conflict of commitment, existing university policies for disputes will be used.
Reason for Policy
It is inevitable that conflicts of interest will sometimes arise. The purpose of this policy is to set out a mechanism for identifying and addressing potential and actual conflicts of interest so that the university’s constituencies can be confident that its decisions and actions are untainted by personal interests.
Policy Scope
All employees of the university including full-time, part-time and student employees, and any other person while acting on behalf of or at the request of the university including, but not limited to, members of a university committee, board members, and persons giving advice to the university at the request of the university and anyone involved in a university decision-making process.
Procedures
Responding to Conflicts of Interest and Commitment
Whenever a university community member has reason to believe that a conflict of interest may exist in the potential employment situation, they must report the facts to the relevant academic dean or unit director so that a determination may be made prior to the actual appointment.
- When a conflict of interest arises during existing employment or when a conflict of interest is anticipated to occur, the employees and/or supervisor must promptly notify the relevant dean or director.
- The dean/director must consult with the Office of Human Resources for assistance in developing an approved management plan or resolving the conflict.
- The Office of Human Resources must consult with the president and university counsel, as appropriate.
- Management plans must be reviewed and signed by the involved parties, the relevant dean/director, the associated vice president or provost, and the Vice President for Strategic Operations & Human Resources.
- Final copies of all approved management plans must be forwarded to the Office of Human Resources which will retain copies.
- The Office of Human Resources, in cooperation with the relevant business unit, will review all approved management plans periodically for effectiveness, but no less than every three years, or as conditions change.
Frequently Asked Questions
Q: What counts as a conflict of interest?
A: A conflict of interest exists when your personal interests could influence, or appear to influence, the decisions you make for the university.
Q: What counts as a conflict of commitment?
A: Outside activities that interfere, or reasonably appear to interfere, with your responsibilities to the university. This includes paid or unpaid work, on or off campus.
Q: Can I have outside jobs or activities?
A: Yes. The university encourages outside activities that enhance its mission. You must disclose any real, suspected, or potential conflict they create.
Q: How do I disclose a conflict?
A: Disclose it right away, in writing, to your supervisor and the Office of Human Resources. Step back from any related discussions, votes, or decisions.
Q: When do I complete the Conflict of Interest Disclosure Form?
A: All employees complete the form at hire, even with nothing to report. Key employees complete it every year. Get the form from the Office of Human Resources.
Q: Can I accept gifts?
A: Not when accepting a gift or hospitality could influence, or appear to influence, your university duties.
Q: What happens after I disclose a conflict?
A: An appropriate university official investigates and evaluates it. Significant conflicts get eliminated or managed through an approved management plan.
Q: What happens if someone fails to disclose a conflict?
A: Violations count as misconduct and may lead to sanctions up to and including termination.
Q: Who do I contact with questions?
A: Contact the Office of Human Resources at 612.343.4412 or hr@northcentral.edu.
Forms
- Conflict of Interest Disclosure Form (obtain from Office of Human Resources)
Appendices
There are no appendices associated with this policy.
Additional Contacts
| Subject | Contact | Phone | |
|---|---|---|---|
| Primary Contact | Office of Human Resources | 612.343.4412 | hr@northcentral.edu |
| Policy Clarification and Interpretation | Office of Human Resources | 612.343.4412 | hr@northcentral.edu |
Definitions
Conflict of Interest
A conflict of interest exists where there is a potential or actual divergence between the personal interests of a university member and that member’s obligation to uphold the interests and mission of the university. In a conflict of interest situation, an impartial observer might reasonably question whether actions or decisions taken by the university member on behalf of the university are influenced by consideration of personal interests. A conflict of interest depends on the situation, and not on the character or actions, of the individual.
Conflict of Commitment
When a university community member’s outside activities interfere, or would reasonably appear to interfere, with their institutional responsibilities. This includes any outside services, dual employment, consulting or other activity, regardless of the location of those activities (on or off campus), the type of entity (for-profit, not-for-profit or government), or the level of compensation (compensated or unpaid).
Gift
Any item, product, or service, regardless of the nature, purpose, or value. The term also includes entertainment such as tickets to events, golf, and other sports outings; hotels, transportation, and other travel expenses, stock, equity, ownership interests, and discounts on products or services.
Financial Interest
Anything of monetary value, including but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and the value of intellectual property rights (e.g., patents, copyrights and royalties from such rights).
Key Employee
An officer whose annual compensation exceeds the key employee threshold set by the Internal Revenue Service under Internal Revenue Code Section 416(i) ($235,000 for 2026).
Personal Interest
The personal, private, or financial interest of a university member or closely associated person or related business.
Report in Good Faith
A report made with an honest and reasonable belief that a university-related violation of law or policy or other instance of non-compliance or related misconduct may have occurred.
Retaliation
Adverse action against an individual because the individual has made a protected disclosure or has participated in an investigation, proceeding or hearing involving a protected disclosure.
University Community Members
All employees of the university including full-time, part-time and student employees, and any other person while acting on behalf of or at the request of the university including, but not limited to, members of a university committee, persons giving advice to the university at the request of the university and anyone involved in a university decision-making process.
Responsibilities
President
- Approve exceptions to this policy and review conflicts as needed.
Deans, Directors, and Vice Presidents
- In consultation with the Office of Human Resources, approve management plans.
Office of Human Resources
- Establish and manage procedures for this policy.
- Advise and educate departments and individuals on resolving conflicts of interest and commitment.
- Draft language for management plans and gain approval for plans by appropriate university officials.
- Store documentation and disclosure forms.
- Work with the president and other university officers to resolve or mitigate real or potential conflicts.
University Community Members
- Inform their supervisor of any workplace personal relationship involvement, conflicts of interest, or conflicts of commitment.
Key Employees
- Annually complete the Conflict of Interest Disclosure Form.
Administrators/Supervisors
- Consult with each individual with the conflict or potential conflict, either jointly or separately. Contact Office of Human Resources. Protect the employment or academic interests of the subordinate. Document consultation regarding conflicts. Keep all documentation secure.
Related Information
Related Policies & Procedures
- Financial Aid Code of Conduct
- Intellectual Property and Copyright
- Nepotism and Personal Relationships
- Whistleblower Protection
History
Amended
2026-10-01 – Non-substantive updates (e.g., titles, contacts, and copy errors); updated the key employee threshold; moved the procedure onto the policy page; added frequently asked questions.
Issued
2019-07-11