5.02 Conflict of Interest

Effective Date: April 1, 2010

Purpose:

This policy is intended to ensure that employees are aware of their obligation to avoid activities and/or situations that may result in a conflict of interest with their College duties; to make decisions objectively and ethically across a wide range of financial and non—financial activities; and to clarify the College’s expectations about disclosure of such situations and activities, should they occur.

Procedure:

An employee shall be considered to have a conflict of interest if:

The employee has existing or potential financial or other interests which impair or might reasonably appear to impair an independent, unbiased judgment in the discharge of his or her responsibilities to the College; or,

The employee is aware that a member of his or her family (which for purposes of this paragraph shall be a spouse, parent, siblings, children and any other relative if the latter resides in the same household as the employee) or any organization in which the employee or member of his or her family is an officer, director, employee, member, partner, trustee, or controlling stockholder, or has such existing or potential financial or other interests, which might impair or might reasonably appear to impair an independent unbiased judgment in the discharge of his or her responsibilities to the College.

Employees neither shall solicit nor accept gratuities, favors or anything of monetary or real value from contractors or potential contractors.

Employees must refrain from real or perceived nepotism (favoritism based on family relationship).

Employees may not appropriate College resources, tangible or intangible, for personal use.

All such conflicts should be avoided or, if discovered or suspected, immediately disclosed to an Officer of the College.

See the following policies for additional relevant information:

4.06 Employment of Relatives 66

5.01 Confidentiality 94

5.03 Conflict of Commitment 101

5.04 Whistleblower Policy 104