Conflict of Interest Policy

General Policy Statement
 
All decisions and actions taken by members of the Sacred Heart community [1] in conduct of University business shall be made in a manner that promotes the best interests of Sacred Heart University. Members of the Sacred Heart University community have an obligation to address both the substance and the appearance of conflicts of interest and, if they arise, to disclose them to the appropriate University representative and withdraw from debate, voting or other decision-making process where a conflict appears to exist.
 
Guidelines
 
The following guidelines contain representative lists of (1) prohibited conflicts and (2) situations that may not be prohibited but must be disclosed for resolution by management. The University relies on members of the Sacred Heart community to apply the University’s mission statement, Conflict of Interest Policy, and commonly accepted rules of ethical and professional conduct to identify conflicts not listed below.
 
The following are examples of Conflicts of Interest that are prohibited:
 
  • Hiring/supervising a family member as an employee.
  • Receipt of duplicative remuneration from Sacred Heart and an outside source for the same services.
  • Use for personal gain of privileged or confidential University information, or assisting an outside organization in obtaining a preferred position by providing such information.
  • Authorizing a consulting contract at Sacred Heart for a family member.
  • Solicitation of gratuities, favors or anything of monetary value from students, donors, vendors or contractors of the University for personal benefit.
  • Voting on the award of University business to a vendor in which one has a significant financial interest or by which one is employed.
  • Authorizing a Sacred Heart donation to or purchase from an organization on whose board one serves.
  • Conditioning any actual or potential University business relationship with a person or business on a charitable gift or contribution to the University.
  • Authorizing University-paid travel for a family member without the President’s approval.
 
The following are examples of possible conflicts of interest. While all such conflicts must be disclosed, they may not be prohibited. Some may be managed through administrative oversight and/or recusal by the disclosing individual. Others may be considered sufficiently resolved through disclosure alone.
 
  • Having a significant financial interest [2] in an organization that either has Sacred Heart as a customer or supports the individual’s University activities.
  • Accepting individual gratuities, favors, gifts, or any other benefit of monetary value equal to or greater than $250 from vendors, donors, students/parents or employees whom you supervise or evaluate at the University. This does not include University-sponsored collections on behalf of the University or individual.
  • Outside activities in which there is more than an incidental use of University facilities, equipment and/or services.
  • Participating in the negotiation of a contract between the University and an organization in which the Sacred Heart community member, a member of his or her family [3] or associate [4] has a significant financial interest.
  • Receipt of consulting fees or other remuneration from Sacred Heart University if one is a member of the University or its Board of Trustees.
  • Participating in a grant or research project with an organization or entity in which the Sacred Heart University member, a member of the family or an associate has a significant financial interest.
 
[1] For purposes of this policy, a member of the Sacred Heart community is an employee of Sacred Heart University, a member of the Board of Trustees of the University, or a person acting as an agent of the University.

[2] Significant financial interest is an ownership interest of more than 5% or a controlling interest in any entity, or being an officer or director in an entity.

[3] For purposes of this policy, a family member is a spouse, domestic partner, parent, child, sibling or permanent resident of the household.

[4] For purposes of this policy, an associate is any individual or organization with whom a member of the Sacred Heart community has a close personal or business relationship such that a benefit to the associate could be construed as a personal favor by the member and/or an indirect benefit to the member personally.