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Institutional Compliance and Internal Audit

Office of Internal Audit

Conflict of Interest

The University of Denver’s mission is regularly served by the participation of its representatives in activities outside the University.  Interactions with external organizations contribute to the enrichment of University programs.  While such interaction is encouraged, these activities may result in a real or perceived conflict of interest.  It is necessary to assess and manage conflicts of interest, so that the integrity and the interests of the University and its representatives are protected.

DEFINITION OF A CONFLICT OF INTEREST

A conflict of interest exists in situations when a University Representative has a significant financial, personal, or professional interest that is directly or indirectly at odds or inconsistent with the University’s interests.  It is not possible to define all situations that might be considered conflicts of interest, and ultimately, the University relies on each University Representative’s sound judgment and common sense.  The most likely conflict situation is one in which a University Representative has a financial interest, direct or indirect, in the business dealings of the University.  Conflicts of interest occur in situations such as when:

  1. An individual’s ability to act independently or objectively in the University’s best interests may be impaired, or might appear to be impaired, by an existing or potential financial, personal, or professional benefit received by the individual;
  2. An individual has a significant financial interest in another entity that supplies, or proposes to supply in the future, funds, goods, or services to the University;
  3. An individual has a relationship with a third party, such as a vendor of goods or services to the University, that results in, or has the potential to result in, personal gain to the individual because of the third-party’s relationship with the University; or
  4. An individual derives, or appears to derive, a financial or other material benefit from confidential information learned in the course of work or service on behalf of the University.

University representatives’ individual interests include the interests of their family members, who are defined as a University representative’s spouse, domestic partner, and dependent children. 

REPORTING PROCESS

Annually, key employees and board members are asked to complete a questionnaire regarding conflicts of interest.  The results of the questionnaire are provided to the Chair of the Audit Committee of the Board of Trustees.  However, all employees are obligated to meet the requirements of the Conflict of Interest Policy, which requires employees to report specified information to supervisors as well as complete the Conflict of Interest Disclosure Form in any instance where a conflict of interest may be perceived.

When a University representative, other than a trustee or the Chancellor, becomes aware of an interest or relationship that might constitute or give rise to a conflict of interest, the University representative must promptly disclose that individual interest to his or her supervisor and the Office of Internal Audit via the Conflict of Interest Disclosure Form.  Trustees and the Chancellor must make prompt disclosures to the Chair of the Audit Committee.  A University representative must also promptly disclose a significant personal, financial, or other interest in any transaction for which he or she is being called upon to exercise his or her University authority.  The University representative must follow up on any verbal disclosures with a written disclosure using the Conflict of Interest Disclosure Form maintained by the Office of Internal Audit.

Potential conflicts of interest for employees are evaluated by General Counsel and the Office of Internal Audit to determine whether a reported concern amounts to an actual or apparent conflict of interest.  For trustees, the Chair of the Audit Committee makes such determinations.