Conflict of Interest

Effective Date

June 12, 2017

Last Revision Date

June, 2023 

Responsible Party

Human Resources


All employees  


This policy applies to all university employees. Marymount University’s (“ University”) goal is to avoid not only conflicts of interest, but also any situation that might give rise to questions about The University’s integrity. It is critical University employees not engage in conduct that constitutes an actual conflict of interest or commitment, or gives the appearance of a conflict of interest or commitment. 

Policy Statement

The purpose of this policy is to ensure that all employees apply the highest ethical principles and standards in the fulfillment of their professional duties and obligations to the University. This policy identifies and resolves issues of ethical conduct that may arise in the course of their day-to-day work, including interactions with the broader community.  An employee who violates this Conflict of Interest Policy (“policy”) is subject to corrective and/or disciplinary action in accordance with the University Progressive Discipline Policy. Instances of deliberate breach of this policy by agents (such as contractors and volunteers) will result in termination of contracts and/or services or dismissal of volunteer assignments. This policy is not intended to supplant, but rather to complement and supplement, existing University policies related to conflict of interest and conflict of commitment, such as those found in the Faculty Handbook or the Board of Trustees Policies. All employees who are subject to other University policies that contain greater restrictions on conflict of interest and conflict of commitment must follow the more restrictive requirements and seek clarification from their Supervisor. In addition, all employees who are subject to codes of ethics or standards through their professional, credentialing or licensing governing bodies must also comply with those standards.

1.0 Conflict of Interest

1.1 Conflict of Interest Generally

Employees are required to act in an ethical manner consistent with their responsibilities to the University and avoid circumstances in which their personal interests and financial or other ties to outside entities or individuals could present an actual, potential, or apparent conflict of interest.  Conflict of Interest means any or all situations that involve personal, familial, business, or financial relationships or interactions involving an that may appear to present, or potentially present or actually does present a conflict between the employee’s own personal, familial, business, or financial interests and the University’s interests or the fulfillment of the employee’s work-related duties. Employees are also subject to any other definitions of conflict of interest which exist in other applicable University policies.

1.2 Disclosing Conflict of Interest

In such situations as described in Section 1.2, an employee must seek prior written approval from Human Resources before accepting such service. In all cases, employees must recuse themselves from participating in any decisions regarding business between the University and the involved third-party organization, as well as any other decisions that could reasonably have a negative impact on the University’s interests.  If it is not clear whether disclosure is needed, employees should err on the side of disclosing to avoid a violation of this policy. Human Resources are responsible for determining whether a conflict of interest exists, and if so, whether it can be effectively managed. This management plan should be communicated in writing to all parties involved.

2.0  Outside Employment

Outside employment or external engagement in a professional capacity can raise conflict of interest or commitment concerns. Employees who wish to engage in outside employment or professional engagement must demonstrate that this poses no conflict of interest or commitment.

2.1 Applicants

Prior to an offer of employment, all employees must disclose, in writing, outside employment or engagement in consulting for others and receive approval to continue that employment. 

2.2  Current Employees

During the course of employment and prior to the commencement of outside employment or consulting, employees must first seek prior approval from their Supervisor before accepting such employment  to ensure that the employment would not present a conflict of interest or commitment, potential conflict of interest or commitment, or the appearance of a conflict of interest or commitment.   

Employees are also required to periodically update outside employment interests when requested by the University. Full-time faculty who are engaged in outside employment will follow the guidelines for disclosure and approval in Section 8.3 of the Faculty Handbook.

  1. Staff will update the conflict of interest form in conjunction with the annual evaluation process.
  2. Faculty will update the conflict of interest form in conjunction with the annual contract renewal process.

2.3  Job Performance

Any employee holding a position with another organization must demonstrate satisfactory performance in his or her job responsibilities with the University at all times. All employees are expected to meet the job performance standards established by the University and will be subject to University’s work and scheduling demands, regardless of any other outside work requirements. Employees are cautioned to carefully consider the demands that additional work activity will create before accepting outside employment. 

Outside employment will not be considered an excuse for poor job performance, absenteeism, tardiness, leaving early, refusal to travel, or refusal to work overtime or different hours. Employees who have accepted outside employment may not use paid sick leave to work on the outside job. Fraudulent use of sick leave will result in disciplinary action up to and including termination.

If determined that an employee’s outside work interferes with his/her job performance or the ability to meet the requirements of University at any time, the employee may be asked to terminate the outside employment if he or she wishes to remain employed with University. A refusal to comply with University’s reasonable request to terminate outside employment may result in immediate termination of employment with The University.

3.0  Employment of Relatives

Employment of Relatives can raise conflict of interest concerns. 

3.1 Definition of Relatives

For purposes of this policy, a current employee’s relatives include his/her spouse, parents, parents-in-law, children, children-in-law, siblings, uncles, aunts, first cousins, step-relations, grandparents, nieces, and nephews, or any other person residing in the same household as the employee.

3.2 Approved to Hire

A relative of a current University employee may be hired for a University position if the employment of the relative does not present a conflict of interest or the appearance of a conflict of interest.  A relative of a current employee may be hired for a position if the individuals who are related by blood, marriage, or reside in the same household have no direct reporting or supervisor to subordinate relationships exist. If two employees marry, become related, or develop any other personal relationship where the potential problems noted above may arise, only one of the employees will be permitted to remain in the department unless the potential or actual conflict of interest can be eliminated or managed.

3.3 Not Approved to Hire

A relative of a current employee may not be hired for a position in the following situations:

  1. If there would be a reporting relationship between the related employees.
  2. If one of the related employees would be in a position to control, approve, and/or review financial transactions prepared or performed by the other.
  3. If one of the related employees would have supervisory authority over the other.
  4. If the related employees would be in the same department. 

4.0  Gratuities, Gifts and Solicitations

Employees shall neither solicit nor accept gifts or gratuities, favors, or anything of monetary value from students, student’s relatives, visitors, or vendors, contractors doing business with, or seeking to do business with the University, or parties to sub-agreements.

Unless specifically excepted by this policy, employees shall not accept non-cash gifts of any type, including materials, services, travel, and attendance at a charitable or similar event as a guest and entertainment at no cost or at unreasonably discounted prices from persons or entities doing (or proposing to do) business with the University. Excepted from this policy are usual and customary:

  1. celebratory business gifts of a value of not more than $75 for the shared use of department personnel;
  2. occasional meals in connection with university business meetings and events and university sponsored or pre-approved charitable, in connection with attendance at professional meetings and similarly sponsored events by industrial, technical, professional, or educational associations, or at public ceremonies in an official capacity or similar events;
  3. review copies of vendor provided textbooks and other teaching related materials or informational material such as books, reports, pamphlets, calendars, periodicals, or other unsolicited promotional material; and 
  4. ceremonial gifts received by university employees in the course of official business. Such ceremonial gifts are the property of the University.

All unpermitted gifts must be immediately declined, returned, or discarded. If any individual or organization dealing with the University offers an employee a gratuity or gift, outside the exceptions listed above, that person or representative should be informed of this policy and any such gratuity or gift should be returned. This policy does not apply to the acceptance of gifts related to fundraising by officers or agents of the University.

No employee may solicit another employee for any purpose while either employee is on working time. The distribution of handbills or other literature during working time or in working areas is forbidden. Persons who are not employed by the University are prohibited from soliciting any employee or distributing literature on university job sites, premises, or at employee work locations at any time.