350 Conflict of Interest
350.01 Conflict of Interest Policy Statement
- The federal regulations under which grant and contract funds are made available to the College require that the administration of those funds be conducted in such a way as to preclude "conflict of interest" practices. Relevant areas would include both purchases of goods and services and employment. In the area of employment, federal auditor’s review for possible evidence that individuals have afforded preferential treatment to persons related to them in appointment and/or promotion actions. Federal and state EEO and Affirmative Action policies and regulations also prohibit discriminatory practices in hiring. The College at Brockport must, therefore, establish a conflict of interest policy, which achieves a balance between preventing preferential treatment for relatives and ensuring that applicants and employers are not subject to discrimination based on family relationships.
- College policy does not preclude the employment of two or more members of the same family. However, to ensure our compliance with federal policy, no employee of the College may recommend or approve any personnel action affecting a relative. This applies to all forms of employment on campus, permanent or temporary, regardless of source of funding (state, IFR, Research Foundation, BASC, Brockport Foundation).
- Where the search and selection process results in a situation in which a College employee finds he or she must recommend or approve the appointment of a relative, the employee must defer to the next administrative level to make the initial recommendation. In forwarding the personnel action to the next administrative level, the employee should include the vita of the proposed appointee, a statement of the position's requirements and salary, and their relationship to the proposed appointee's qualifications; and a summary of the recruitment and selection process, including the names of the other candidates considered and the basis for their rejection. The review at the next administrative level shall be based on the relationship of the proposed appointee's qualifications to the requirements and salary of the position, the qualifications of other interested candidates, and any other extenuating, job-related circumstances. The review should also involve consultation with the Director of Human Resources.
- If the appointment is recommended by the next administrative level, the case will proceed through normal channels. If it is not approved, the case will be returned to the employee so that another candidate can be recommended.
- If an employee finds that he/she is responsible for the direct supervision of a relative, the employee must make arrangements with his/her supervisor for an appropriate means of removing himself/herself from any process, which evaluates or otherwise considers the relative for reappointment, continuing or permanent appointment, promotion, or salary adjustment. Arrangements must also be made for the independent verification of attendance and leave records and effort reports. The arrangements must be placed in writing with a copy to the Office of Human Resources and a copy to the Director of Sponsored Research and Contract Administration for persons employed through the Research Foundation.
Return to Work Related Policies - Personnel Related