Conflict of Interest, Ethical Conduct and Purchases of Goods and Services from Related Parties
Kenyon College respects the privacy of every trustee, administrative officer, member of the faculty, and employee in the conduct of their personal affairs. Nevertheless, institutions should take reasonable precautions against conflicts of interest.
Conflict of Interest
A conflict of interest would be deemed to exist if a trustee, officer, member of the faculty, employee or spouse/domestic partner or dependent children of any of the above, as a result of their position at the College, would derive directly or indirectly, personal benefit, financial or otherwise, through dealings with, or employment by others with which the College has professional, financial, or business relationships, except where such dealings or employment are in the best interest of the College and/or have been expressly approved by the trustees or the president of the College.
A conflict of interest or potential conflict of interest would also exist if anyone applying for Federal funding (i.e. grant proposals) would have significant financial interests that would appear to be directly and significantly affected by the research or educational activities funded or proposed for funding to a Federal agency. The term ‘significant financial interest’ means anything of monetary value, including but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., patents, copyrights and royalties from such rights.)
In order to fulfill the Board’s responsibilities in regard to the policy, the secretary shall send to each trustee and officer, before the October meeting of the Board, a statement of this policy with the request that the Conflicts of Interest Procedures form be completed, signed, and returned to the secretary. The president’s chief of staff shall do the same for each of the senior administrative officers of the College, and for any other faculty or staff member who is in a sensitive position as regards conflict of interest and/or ethical conduct and give a full report on this matter to the Board upon request by the chairman. The financial officer of the College shall do the same for any faculty member or employee applying for Federal funding (i.e. grant proposals.) If any actual or potential conflict of interest is discovered by the financial officer, the grant proposal will not be approved for submission until such conflicts or potential conflicts are resolved. If a conflict of interest is discovered after a grant proposal has been submitted and approved, the College may require divestiture of significant financial interests and/or severance of relationships that create actual or potential conflicts. The financial officer shall require the above-referenced form to be completed at the time the grant proposal is submitted and will update the disclosures during the pendency of the award as new reportable significant financial interests are obtained. It is the responsibility of the employee submitting the proposal and or receiving funding to notify the financial officer of the College of any such changes requiring disclosure.
Employees of Kenyon College accept responsibility for conducting the affairs of the College consistent with the objective to sustain and further the core mission of the College; to provide the best educational experience for Kenyon students and to provide the proper environment for that mission through the responsible stewardship of the College’s financial and physical resources.
Standards of ethical conduct also preclude unauthorized disclosure of confidential information.
Purchases of Goods and Services from Related Parties
Employees of the College shall exercise the utmost good faith in all transactions, activities and behaviors related to their duties to Kenyon College and its property and resources. Any situation in which there is a divergence between the employee’s private interests and professional obligations to the College, such that an independent observer might reasonably question whether the employee’s actions or decisions are determined by consideration of private gain, whether financial or otherwise, to the College’s detriment must be avoided. Such a situation may result from consulting or other outside employment, a relationship defined as a related-party interest, or any other relationship that results in a gift or benefit to the employee.
Employees should not personally benefit from transactions entered into by the College or when a member of the employee’s family or related businesses (see definitions below) will benefit, unless it is in the College’s best interest to do so as determined by the designated College official defined in the reporting procedure below. Transactions include, but are not limited to: originating purchase requests, influencing purchasing decisions, and consulting or professional relationships that are created or perceived as creating a conflict of interest. Kenyon College does acknowledge that due to the College’s rural setting, with limited service or supply providers in some specialties, it is possible that it would be appropriate for an employee or their family related business to conduct financial transactions with the College.
Reporting Procedure: Any person who is aware of a potential conflict of interest in purchases and services from related parties as described in this section should notify their Division Head.
Family: For the purposes of this policy, this means a person who is related to an employee as a spouse and/or domestic partner or children or parents thereof; or any relatives related by blood, marriage or adoption to the preceding.
Related Businesses: For the purposes of this policy, this means any individual, entity, corporation, firm, association, union, trust, estate, as well as any parent or subsidiary of the foregoing, and whether or not operated for profit, with which the employee is directly engaged in business for personal profit.