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.