Conflict of Interest

More Than One University Position

It is unusual for a staff member to be employed by more than one department of the university. Any such arrangement should be coordinated in advance by the area vice presidents in consultation with Human Resources. A full-time staff member may teach a course at the university so long as the course is not offered during the regular work day, does not interfere with the staff member's regularly-scheduled duties, and has the approval of the appropriate vice president. Staff members who teach courses outside of the regularly-scheduled work day are eligible for compensation for those teaching duties when the teaching duties are in addition to their normal responsibilities. Such compensation will be determined by the Office of the Academic Vice President and Dean of the University.

Outside Employment

The university does not prohibit a staff member's employment outside of the university. However, outside employment must be handled in such a way as to avoid conflicts of interest.

To assure the university that a staff member is able to fulfill his or her obligations to the university and to insure those obligations are not impaired when undertaking outside employment, consulting, business, professional or teaching activities, the principles in this policy statement shall be used, as far as possible, as appropriate guidelines.

If a staff member is a director, president, partner, general manager, or similar executive officer, or owns or controls directly or indirectly a substantial interest in any other entity participating in a transaction with the university, a conflict of interest may exist. Staff members are required to conduct activities on behalf of the university with good faith and may not compete with the university or use business opportunities, confidential information, or trade secrets of the university for personal gain or advantage, or for the gain or advantage of another.

Staff members shall not knowingly accept an engagement which is likely to embarrass the university or involve the university in unwarranted controversy or will involve a conflict of interest between the individual's university responsibilities and outside work. Staff members must inform their supervisors and receive written approval before engaging in any outside activities that have the potential for conflict of interest. Failing to report such activity immediately-or continuing an activity without the supervisor's written approval-may be grounds for corrective action, including termination of employment.

Outside employment, business or consulting activities shall be scheduled outside of the staff member's normal work week or shall be scheduled during the staff member's vacation leave.

University offices, facilities, staff or stationery shall not be used in the conduct of a staff member's outside business. A staff member engaged in outside business activities, with or without compensation, should not use the name of the university to suggest institutional endorsement or support of a non-university enterprise and should not use the name of the university on stationery, business cards, or promotional literature for such outside activities.

Staff members must conduct any business related to their outside activities completely separate from the university. For example, billing should not be done from or payments mailed to the staff member's university address.

The staff member should make clear, verbally and in writing, to outside employers, clients, consultees, or customers that their outside employment, business or professional services are independent. No relation of such outside activities to the University of Puget Sound shall be stated or implied.

When the outside consultation or business activity is of a nature that an element of potential risk or liability is involved, the staff member should carry his or her own independent professional liability insurance.

Employment of Relatives

The university allows the simultaneous employment of more than one member of the same family or household. However, employment of more than one member of the same immediate family or household must be handled in such a way as to avoid conflicts of interest or the appearance of conflicts of interest.

The following are examples of business necessity situations where employment of more than one member of the same immediate family or household may be limited:

• Where an individual would have the authority or practical power to supervise, appoint, remove, or discipline a member of the same immediate family or household;
• Where an individual would be responsible for auditing the work of a member of the same immediate family or household;
• Where other circumstances exist which would place members of the same immediate family or household in a situation of actual or reasonably foreseeable conflict between the university's interest and their own; and
• Where, in order to avoid the reality or appearance of improper influence or favor, or to protect its confidentiality, the university must limit the employment of relatives of policy level officers of customers, competitors, regulatory agencies, or others with whom the university deals.

The immediate family for this purpose includes: spouse, child (including foster child and step-child), parent (including legal guardian and step-parent), parent-in-law, grandparent, grandchild, sibling, sibling-in-law.

In some cases a concern over conflict of interest may arise involving other close relatives-such as aunts, uncles, cousins, or relatives by marriage-or unrelated persons who share housing with staff members. In these cases, the staff member should fully disclose the circumstances in writing to his or her supervisor. Such circumstances should be addressed on a case-by-case basis in consultation with the Human Resources Department.

Origination Date: 9/1958
Revised: 1996