Conflict of Interest

Procedure no. I-3a
Effective date: 01/01/2002
Related Policy: I-3

Goal: To comply with the Board of Trustee's directive to adopt and carry out the Conflict of Interest Policy.

Administrative Approval
For Staff: Audit Committee
For Faculty: President
For Student Employees: Audit Committee

Functions Impacted
Human Resources
Student Employment

Detailed Procedures
  1. The President shall designate the university officers responsible for requesting confidential information periodically from university officers, administrators, staff, student employees, and faculty. The responsible officers shall do so using the Disclosure of Potential Conflict of Interest Form (#HR30010101) (pdf) to aid in disclosing apparent conflicts of interest. It is understood that at this stage they may share confidential information only with each other and the President. These officers may, in instances of apparent conflict involving faculty members, consult with the appropriate vice president and/or dean with whom they may share confidential information for this purpose.
     
  2. The designated university officers, having identified an apparent conflict of interest at Case Western Reserve University, shall consult with the individual involved in an attempt to resolve the apparent conflict in a manner consistent with the best interests of the university and the rights of the individual, while maintaining the highest ethical standards.
     
  3. University officers shall refer such conflicts as they are unable to resolve as follows:
     
    1. In the case of university officers, administrators, staff, and student employees, to the Audit Committee of the Board of Trustees for its recommendations, which shall be transmitted to the Executive Committee of the Board of Trustees.
       
    2. In the case of faculty members, to the President who may inform the Audit Committee and who may discuss the problem with and seek the advice of the Executive Committee of the Board of Trustees. The President, with the concurrence of the Executive Committee, may invoke procedures for dealing with breaches of the standards of professional ethics, which are specified in Policies and Procedures for the Faculty of Case Western Reserve University.
       
  4. The Executive Committee of the Board of Trustees shall resolve conflict of interest matters referred to it by determining a course of action that will best serve the university's interests and that will be in accordance with the highest ethical standards.
     
  5. The Human Resources Department will review the Conflict of Interest Policy with all newly hired staff employees and make the disclosure form available to them. Student Employment will review the Conflict of Interest Policy with student employees and make the disclosure form available to them.
     
  6. The Chief Finance and Administrative Officer will periodically distribute the Conflict of Interest Policy with the disclosure form to all employees.
     
  7. On an interim basis, employees who identify a newly-arisen potential conflict will first contact their immediate supervisors and then complete the disclosure form and submit it to the Chief Finance and Administrative Officer for review and resolution.