All Employees
Page at a Glance:
- What is the University of California's Conflict of Interest policy for employees?
- What is the University of California's Conflict of Interest Code for employees?
- Can University employees accept gifts and gratuities?
- What is a personal financial interest?
- What actions must University employees take to avoid a conflict of interest?
- Related Resources
What is the University of California's Conflict of Interest Policy for employees?
The University of California's overall conflict of interest policy stipulates that employees shall not engage in any activities that place them in a conflict of interest between their official duties and any other interest or obligation. The primary legislative document governing conflict of interest and related issues is the State of California Political Reform Act.
The University of California has comprehensive and interrelated policies and guidelines that address the conduct of UC employees, their interactions with private industry and conflict of interest. The Compendium of Specialized University Policies, Guidelines, and Regulations Related to Conflict of Interest is a collection of complementary policies and guidelines that work together to set high standards for employees, ensure the integrity of UC research results, and guide interactions of UC employees in their partnerships with industry and other university-related activities.
What is the University of California's Conflict of Interest Code for employees?
The University of California adopted a Conflict of Interest Code, which is revised annually and submitted to the California Fair Political Practices Commission for approval. The Commission is the state body that administers, interprets and enforces the State of California Political Reform Act (the Act). The Act places the responsibility upon the individual to be familiar with the requirements of the Act and with the University of California Conflict of Interest Code. Violation of the Act subjects the individual, not the University, to administrative, civil and criminal penalties.
Can University employees accept gifts and gratuities?
University of California employees shall comply with the provisions of State and Federal law and the UC Policy and Guidelines Regarding Acceptance of Gifts and Gratuities by Employees.
All University employees are expected to act with integrity and good judgment and to recognize that the acceptance of personal gifts from those doing business or seeking to do business with the University, even when lawful, may give rise to legitimate concerns about favoritism depending on the circumstances. If a University employee has any question regarding the propriety of a gift, disclosure of the gift or proposed gift, they should ask a supervisor or the UCSD Conflict of Interest Coordinator for a determination of the proper course of action.
Example:
- An Associate Director at UCSD was asked to appear on a panel at a symposium in Denver, scheduled for later in the month. The panel is being put together by a vendor that is used here at UCSD. They are paying all expenses related to be appearing on the panel (airfare, hotel, & food). Is there anything inappropriate with the Associate Director being on this panel and having this vendor pay all expenses?
- In accordance with University policy on the acceptance of gifts and gratuities, it is permissible for this vendor to pay for your lodging and meals, since your proposed travel is in conjunction with speaking on a panel. These payments would not be considered as gifts to you, and would not preclude you from participating in any University decisions regarding contracting with this vendor. And since the actual transportation costs are for an event outside the State of California, the airfare, if greater than
$420, would be considered as a gift to you. Once an outside entity gives you a gift in excess of $420, you would be disqualified from participation in any University decisions regarding contracting with the entity. Therefore, it is recommended that your UCSD department pay for your airfare and the vendor pay for your lodging and meals. For further detailed information, click here.
What is a personal financial interest?
The Political Reform Act prohibits University employees from participating in University decisions when personal financial interests may be affected by those decisions. A University employee has a personal financial interest in a decision if it is reasonably foreseeable that the decision will have a material financial effect, distinguishable from its effect on the public generally, on the employee, a member of his or her immediate family (immediate family means the spouse, including a registered domestic partner, and dependent children) or on any of the following:
- Any business entity in which the University employee has an investment worth $2,000 or more;
- Any real property in which the University employee has an interest worth $2,000 or more;
- Any source of income (except gifts or loans by a commercial lending institution made in the regular course of business on terms available to the public without regard to official status) totaling $500 or more in value provided to, received by or promised to the University employee within 12 months prior to the time when the decision is made;
- Any business entity in which the University employee is a director, officer, partner, trustee, employee, or holds any position of management;
- Any donor of, or any intermediary or agent for a donor of, a gift or gifts totaling $420 or more in value provided to, received by or promised to the University employee within 12 months prior to when the decision is made.
University employees must not make a decision or attempt to influence a decision if they have an economic interest in the entity doing business with the University.
What actions must University employees take to avoid a conflict of interest?
University employees must disqualify themselves from participating in a University decision if a financial conflict of interest is present. If it is determined that your financial interests require you to disqualify yourself from making or participating in the making of a University decision, you must refrain from participating in any way in the decision, and you must not use your official position to influence any other person with respect to the matter.
