EMPLOYEE CONDUCT - CONFLICT OF INTEREST

Reference: Wyoming Statutes, Title 9, Administration of the Government, Chapter 13, Government Ethics Article 1, Public Officials, Member and Employees Ethics, 9-13-101 through 9-13-109

College employees are expected to meet the highest standards of integrity and ethical behavior and to act in the best interest of the College. Employees are to avoid conflicts of interest and carefully keep separate the interests of the College and the employee’s personal, professional and business interests. This includes avoiding actual, apparent, potential, or the perception of conflicts of interest.

The President shall establish procedures regarding conflict of interest and the ethical conduct of College employees.

Procedure 4420A

EMPLOYEE CONDUCT - CONFLICT OF INTEREST

Reference: Wyoming Statutes, Title 9, Administration of the Government, Chapter 13, Government Ethics Article 1, Public Officials, Member and Employees Ethics, 9-13-101 through 9-13-109

College employees are expected to meet the highest standards of integrity and ethical behavior and to act in the best interest of the College which includes avoiding conflicts of interest.

An actual, apparent, potential, or the perception of a conflict of interest occurs when an employee is in a position to influence a decision that may result in personal gain for the employee or a relative of the employee.

Wyoming Statutes state, “No public official, public member or public employee shall use his office or position for his private benefit. As used in this section, “private benefit” means the receipt by the public official, public member or public employee of a gift which resulted from his holding that office.” In addition, the acceptance of a bribe constitutes corruption and may be punishable by law.

Wyoming Statutes define family or relative as an individual’s spouse, child, parent, grandparent, brother, sister, parent-in-law, brother-in-law, sister-in-law, nephew, niece, aunt, uncle or first cousin, and this procedure includes any other person living in the employee’s household.

Prohibited Conduct

• Employees are prohibited from using their job title, the College’s name, and/or College property for private profit or benefit.
• Employees shall not engage in any activities or relationships, including personal investments, which might directly or indirectly result in a conflict of interest or impair their independent judgment. Employees must not accept gifts of more than $50 in value, favors, or benefits that might tend in any way to influence them in the performance of their duties. This includes, but is not limited to, selecting, awarding or administering a contract or purchase order; or any decisions involving the administration of the College.
• Employees shall not participate in selecting, awarding, or administering any purchase or contract on behalf of the College where, to the employee’s knowledge or information, any of the following has a financial or personal interest in said purchase or contract:
  a) The employee;
  b) A member of the employee’s family or household;
  c) An organization in which the employee, family or household member is an officer, director, or employee;
  d) A person or organization with which the employee, family or household member is negotiating employment or has any arrangement concerning prospective employment.
• Employees shall not provide, in the performance or their duties, preferential treatment to relatives or to organizations in which they or their relatives have an interest, financial or otherwise.
• Employees who hold an outside office or employment shall not place themselves in a position where a conflict of interest raises doubts about their ethical ability to perform their College duties.

Disclosure of Potential Conflicts
Employees must promptly disclose to the appropriate Vice President or President material information regarding any relationship, ownership or business interest (other than non-controlling investments in publicly-traded corporations), whether direct or indirect, that the employee or a member of his/her immediate family has with any person, or in any business enterprise which could be construed to be an actual or potential conflicts of interest.

The President must promptly disclose any reported direct or indirect conflict of interest to the President of the College Board of Trustees. Following such disclosure, employees should recuse themselves from direct involvement in any decisions regarding that business or financial enterprise as it concerns the College - unless the College determines otherwise.

Violation of the Conflict of Interest Policy
Any employee found to be in violation of this Conflict of Interest policy could be subject to disciplinary action, up to and including a recommendation for termination from employment.

Adopted August 8, 2013
Revised July 15, 2015