We have a pretty comprehensive Conflict of Interest policy and process. It includes nepotism. For example, we cannot hire a student employee in any central IT job if a family or step-family member is an employee in IT, even if on different teams reporting up to different managers. Internal Audit runs periodic reports examining addresses to identify possible conflicts on an ongoing basis. HR monitor benefits. Monitoring is pretty pervasive - including software purchases seen below.
The over-arching policy mandated by our Board of Trustees is posted here: https://wwwp.oakland.edu/policies/generalgovernance/406/ Employees of a certain level are mandated to submit an Annual Disclosure: To 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. Participation is annual ethics awareness program is provided: The 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) There is standing committee that oversees reported conflicts, and each individual self-report conflicts as soon as they are known: 1. Conflict of Interest Review Committee A Conflict of Interest Review Committee is hereby established whose members are the: (a) Internal Audit Director, (b) Purchasing Manager, and (c) Assistant Vice President for Human Resources, or the successors to those positions ("CRC"). 2. Duty to Promptly Self-Disclose/Report/Inquire-About Conflicts of Interest As soon as the conflict of interest becomes known, Trustees and the President will report their own conflicts of interest and those of others to the chairperson of the board, the chairperson of the board's audit or successor committee, or designee in writing; and everyone else will report their own conflicts of interest and those of others to the CRC in writing. The university may also require that a person or entity being considered for an arrangement with the university disclose conflicts of interest. Every time we hire, each person on the interview committee must confirm they have completed a policy review and watched the video attached at the end of the policy, and that they have disclosed any relationships. Every time someone buys a technology solution, they have to answer these questions: Have you reviewed university policy #406 Conflict of Interest? (http://www.oakland.edu/policies/406) Is the employee requesting purchase or use of this software friends with vendor employees? Does the employee requesting purchase or use of this software have a personal relationship with any vendor employees? Have all possible conflicts of interest related to purchase or use of this software been reported to a member of the Conflict of Interest Review Committee? Theresa Theresa Rowe Chief Information Officer Oakland University On Wed, Aug 24, 2016 at 1:03 PM, Nicole Goodman <[email protected]> wrote: > I was wondering if any of your institutions have a process of maintaining > information on disclosed relationships. We ask the question “do you have > any family employed by Western?” upon hire to avoid supervisory conflicts > but we need a better way of having that information for when, for example > budget authority is established which can be much later following hire. > > > > Best, > > Nicole > > > > Nicole Goodman > > BFA Budget Officer and Internal Controls/BFA Policy Coordinator > > OM 403, MS – 9044 > > Western Washington University > > (|360.650.2477 6|360.650.3037 +| [email protected] > > [image: Description: Description: Full color logo, small size] > > *Active Minds Changing Lives* > > > > > > *Replying to Messages:* Replying (using Reply) to an ACUPA-L e-mail will > distribute your message to the *ENTIRE list of members*. To send a > message privately, reply directly to the individual who sent the message > (their e-mail address appears in the "From" line of their original e-mail). > > *To Unsubscribe*: Go to http://www.acupa.org/MembershipForm_Discontinue. > html and complete the form. We will remove you from the list within 24 > hours, during normal business hours. > > *Questions about the ACUPA e-list?* Contact Jamie Parris at > [email protected] > <[email protected]?subject=ACUPA%20e-list%20assistance> or > 607-255-6837. > >
