406 Conflict of Interest Policy
|SUBJECT:||CONFLICT OF INTEREST POLICY|
|AUTHORIZING BODY:||BOARD OF TRUSTEES|
|RESPONSIBLE OFFICE:||GENERAL COUNSEL'S OFFICE|
|DATE ISSUED:||NOVEMBER, 1981|
|LAST UPDATE:||DECEMBER 2016|
OAKLAND UNIVERSITY BOARD OF TRUSTEES
CONFLICT OF INTEREST POLICY
Approved by the Board of Trustees on December 5, 2016
Article IThe purpose of this policy is to express the Board of Trustee's intent that trustees, faculty, staff, and others serving Oakland University should not be personally involved in any arrangement that could create a conflict of interest with the university. Everyone who serves the university should promote the best interests of the university over their own personal and financial interests. Conflicts of interest occur in a complex society. Everyone who serves the university must report their own conflicts of interest and those of others to the university as soon as they become known so that the conflict of interest can be promptly and properly managed. This policy will be interpreted and applied broadly.
Article IIConflicts of interest are those personal and financial interests, whether actual, apparent or possible, the could lead someone to: (a) compromise or lose their own independence, impartiality or judgment in connection with an arrangement with the university; (b) propose or support an arrangement with the university that is not in the university's best interest; (c) results in personal or financial gain to that person; (d) involves preferential treatment to the person's family or business associates; or (e) would damage the university's reputation or erode the public's confidence in the university.
Conflicts of Interest
Article IIITo maximize awareness of conflicts of interest, each year trustees, executives, deans and directors must submit a signed written disclosure that affirms they will comply with this policy, and informs the university of their personal, financial and business interests and those of their family and business associates that could involve an arrangement with the university. Trustees and the President will deliver their disclosures to the chairperson of the board, the chairperson of the board's audit or successor committee, or designee; and everyone else will deliver their disclosures to the Conflict of Interest Review Committee. The written disclosures will be maintained in confidence by the university to the fullest extent permitted by law.
Annual Written Disclosures
Article IVThe Vice President for Finance and Administration, or designee, will publicize this policy to the university community and conduct an annual ethics awareness program that will inform people what a conflict of interest is and how to report them to the university. (See Appendix)
Ethics Awareness Program
Conflict of Interest Review Procedures
1. Conflict of Interest Review Committee
(d) Gift. A gift is anything of value in any form including money, goods, entertainment, services, use of
Article VINo one may use confidential information acquired in service to the university for any purpose other than university business, or give confidential information to any person or entity without the prior written consent of the university. If a person becomes aware of a business, investment or other potentially valuable opportunity that rightfully belongs to the university, that person must bring the opportunity to the university.
Confidentiality and Appropriation of University Opportunities
Article VIINo arrangement undertaken by the university is void or voidable or may be challenged by a third party under this policy.
Actions Not Void or Voidable
Article VIIIThis policy supplements but does not replace any applicable State of Michigan or federal law that governs conflicts of interest; and in all cases of federally sponsored grants and contracts, the regulations and procedures necessary to meet federal agency conflict of interest requirements will control. The Board of Trustees is responsible for assuring compliance with this policy directly or through its appointed committee.
SCOPE AND APPLICABILITY:
RELATED POLICIES AND FORMS:
Conflict of Interest - Policy 406