It is the policy of Saint Louis University that the highest standards of conduct and honesty are expected of all employees of the University, and especially of the Chief Executive Officer, administrative staff members, faculty members with administrative responsibilities, and certain other employees having responsibility for committing or encumbering University funds.
Further, a mechanism shall be provided for disclosing and ethically resolving conflicts of interest which may occur in the performance of the assigned duties of these personnel.
This policy applies to all personnel with administrative responsibilities within the University, including the Health Services Division, and to non-administrative employees who as part of their regular assigned duties commit or cause to be committed the resources of the University.
A conflict of interest is considered to exist in any instance where an individual's actions or activities on behalf of the University also involve the obtaining of an improper gain or advantage to the individual, or an adverse effect on the University's interests. It can also result when the conflict of interest prevents the employee from exercising due care, skill, and judgment on behalf of the University in the performance of the individual's assigned duties.
These conflicts of interest can take many forms, including but not limited to the following:
To hold, directly or indirectly, a position or a material financial interest in any outside organization, corporation, company, partnership, or other entity which the individual has reason to believe provides, or proposes to provide, goods or services (including the sale and/or purchase or stocks, bonds, other securities, or real estate) to the University or that provides, or proposes to provide, services competitive with the University. To render directive, managerial, or consultative services to any outside concern that does, or proposes to do, business with the University, competes with the University, or to render other services in competition with the University.
To disclose or use information relating to the University's business for the personal profit of the individual or his/her immediate family (as defined below.)
Immediate family, for the purpose of this policy, is defined as spouse, children, mother, father, siblings, mother-in-law, father-in-law, or any other relative living in the individual's household.
On an annual basis, this policy will be reviewed with all administrative staff members as a basis for reaffirming the commitment of the University to the standards of conduct expected of all University personnel in the performance of their assigned duties.
A listing will be developed by the administrative vice presidents of all personnel who fall within the scope of this policy. The list will include all administrative staff members, faculty with administrative responsibilities, and any employees who, on a regular basis, have both the authority and responsibility to commit the University to contractual relationships, or commit or encumber the funds of the University, whether general operating, restricted, or designated in nature.
For functional purposes, the list will include all personnel within the University who hold the title and/or responsibility normally accorded to director-level positions and above, or as specifically designated by the administrative vice presidents of the University.
Annually, all personnel who have been identified and are shown on the list in Number 2 above, will receive a disclosure statement showing two categories of potential areas of conflict of interest and an attestation statement regarding gifts, gratuities, and entertainment. Each individual receiving the statement will be required to complete and sign the disclosure statement, identifying any potential or existing conflicts of interest or attesting to the fact that there were no areas of potential or existing conflicts of interest, and attesting to the fact that no gifts, gratuities, or excessive entertainment were received.
The completed, signed statements will be returned to the respective administrative vice presidents for their initial review. All disclosure statements will then be forwarded to the Director of University Audit Services who will tabulate the responses and comments and provide a detailed report to the President and the Audit Committee of the Board of Trustees.
All individuals listed will be responsible for providing notification to the appropriate administrative level of any instances of conflict of interest which may occur in the interim period between the dates of the regular annual reporting.
Each individual is also responsible for reporting any potential or existing conflicts involving other personnel subject to this policy of which the individual may become aware.
Failure to fully disclose any potential or existing conflicts of interests may result in disciplinary action.