Financial Conflict of Interest 5.8-2

Introduction

The University respects the rights of its employees in their activities outside their employment at Saginaw Valley State University which are private in nature and which in no way conflict with or reflect upon the University. It is vitally important that the University, a public institution, avoid even the appearance of impropriety, including the inference that certain prospective vendors might enjoy an unfair advantage in doing business with the University by virtue of the employment relationship of its owner with SVSU.  We believe that our employees have been carefully selected and that we can trust their integrity, judgment and courage. The following statements of policy are made to avoid any misunderstanding.

Policy Statement

Each employee must avoid incurring any kind of financial or personal obligation which might affect his or her judgment in dealing for the University with outside firms or individuals. Employees must examine their own activities and those of their families (significant other, parents, brothers, sisters, children, grandchildren, nieces, nephews, and significant others of brothers, sisters, children and grandchildren) to be sure that no condition exists which creates a conflict of interest or apparent conflict of interest with respect to transactions of the University.

1. There are certain areas in which each individual must be especially concerned. Where there is any question about a conflict of interest, even though it may not exist in actuality, the particular situation must be disclosed in writing and filed with the Human Resources Office and/or Business Services Department within 30 days of becoming aware of a potential conflict. The areas about which care should be exercised include the following:

A. Borrowing money from suppliers, individuals or firms, except for financial institutions with whom the University does business.

B. Accepting gifts or favors for oneself or for any member of one's immediate family, or entertainment or other personal obligations, from an outside organization or individual which are substantial enough to influence one's selection of goods and services for the University. This does not apply to acceptance of perishable or consumable gifts of a nominal value of $50 or less, nor reasonable personal entertainment; but care must be exercised to be sure that continuation of such matters does not gradually build up into a potentially improper obligation. Any gift that is of a substantial nature should be returned to the donor with the explanation that University policy does not permit the acceptance of the gift. The University will take care of the expenses of returning such gifts.

C. Acquisition by purchase or lease of real estate in which it is known the University has an interest, or which may improve in value because of the University's interest in adjoining property.

D. The misuse or unauthorized release of information to which the employee has access by reason of his position, such as the disclosure of confidential information to competitors or others outside the University.

E. Holding a financial interest of 5% or greater (that is, any stake, including stockholder, partner, joint venture, creditor, guarantor, or director) in a firm which provides services or supplies, materials or equipment to the University.

• However, no company or firm in which an employee of Saginaw Valley State University or any member of such employee's immediate family holds an ownership interest of five percent (5%) or more shall be considered a vendor eligible to do business with the University. This policy shall remain in effect and applicable to any such company or firm for a period of time extending two (2) years following the termination of employment at the University by any such owner

2. A holding not exceeding 1% of any class of security of a publicly-traded corporation will not be deemed a violation of this policy.

If a potential conflict arises during the year, a statement should be filed with the Human Resources Office or Business Services within 30 days of becoming aware of any potential conflict. It shall be the responsibility of the President (or designee) to determine whether conflicts of interest do exist and to take such steps to protect the University as required.

Exceptions

An exception may be granted to this general policy only upon specific determination by the University President (or designee) that the best interests of the University would not be well served by refusal to enter into a transaction with a particular vendor and that the transaction in question has not resulted from any unfair advantage available to the owner of the prospective vendor by virtue of his or her employment at the University.