All faculty and staff employees
The mission of the University is to promote learning through teaching, research, scholarship, creative accomplishment, and service. As a natural outgrowth of the University’s mission, it may be appropriate and desirable that Members of the University (hereinafter “Members,” defined as full-time and part-time faculty and staff employees of the University)be professionally involved in outside activities such as lecturing at other institutions, practicing their profession, consulting and serving in professional and community organizations. Such activities can enrich teaching, extend professional expertise, and contribute to the advancement of knowledge. In addition, it is recognized that Members may from time to time have ownership interests in, compensation arrangements with, or various other relationships involving third parties with whom the University conducts business. It is also recognized that Members may have family members who are also employed at Syracuse University with whom they may have contact in the normal course of their employment.
While outside activities are generally encouraged and other relationships may be permitted, in some circumstances they can give rise to apparent conflicts. These conflicts can exist when a Member has certain financial or other interests or relationships or when there is a commitment of time or effort to non-University activities that impedes a Member from meeting his/her obligations to the University. For the purposes of this policy “Conflict of Interest” and “Conflict of Commitment” have been defined as follows:
- Conflict of Interest occurs when a Member is in a position to influence a decision on University policies, purchases, programs or decisions from which he/she or a family member or other associate might directly or indirectly receive a benefit. Such benefits can include, but are not limited to, receipt of a financial gain, gift, gratuity, favor, notoriety, or participation in nepotism or bribery.
- Conflict of Commitment arises when a Member’s involvement in outside professional or work activities substantially interferes with his/her primary commitments to the University. Such interference can include, but is not limited to, performance of outside activities (i) during a Member’s work hours for the University, or (ii) other than during work hours to an extent that renders the Member incapable of satisfactorily performing his/her responsibilities to the University.
Conflicts of interest that relate to an investigator’s financial interests being affected by research, scholarship, education or other externally funded activity are covered under Section 3.08 of The Faculty Manual.
Conflicts of Interest or Commitment may occur even though a Member’s outside activities involve comparatively little time.
If a Member engages, or proposes to engage, in any activity that involves any actual, potential, or apparent Conflict of Interest or Conflict of Commitment, the activity and the conflict(s) must be promptly disclosed in writing to the University Administrator (i.e., supervisor, director, dean, department chairperson, vice president, senior vice president, executive vice president, or vice chancellor) having the most immediate supervisory relationship to the Member, before the Member engages in or continues his/her engagement in the activities that produce the conflict.
- Members of the Chancellor’s Cabinet, corporate officers and other selected key employees as may be required by the University bylaws and/or federal or state law shall complete and deliver to the Conflicts of Interest Administrator, on an annual basis and whenever prior responses have materially changed, a Conflicts of Interest/Commitment Questionnaire in the form prescribed by the Chancellor.
- All full-time and part-time faculty and staff employees of the University, excluding those represented by a collective bargaining unit , shall complete and deliver to the University’s Conflicts of Interest Administrator, on an annual basis and whenever prior responses have materially changed, a Conflicts of Interest/Commitment Questionnaire in the form prescribed by the Chancellor The Conflicts of Interest Administrator shall ensure that the appropriate University Administrators are informed of conflicts existing within their respective areas of responsibility and will assist in the development and monitoring of Conflicts of Interest management plans as necessary.
All submitted Questionnaires shall be kept on file for such period of time as may be determined appropriate by the Chancellor, or the Conflicts of Interest Administrator, as applicable.
University Administrators shall use their best efforts to resolve conflicts reported to them consistent with the mission of the University, but may prohibit an activity that produces a conflict in its entirety if they determine that such resolution is not possible. Any appeal of a University Administrator’s decision can be made through the appropriate supervisor, director, dean, department chairperson, vice president, or senior vice president, with final appeal to an executive vice president or vice chancellor. Any decision of a University Administrator must be in writing, and it is the responsibility of the Member, as well as the University Administrator, as the case may be, to ensure that a written decision is provided.
In addition to the disclosures required by this Policy and Policy 3.08 of The Faculty Manual, policies 3.02 through 3.04 of the Faculty Manual and the Outside Professional Consulting by Non-Faculty Employees policy set forth additional requirements that must be fulfilled in connection with a Member’s outside professional consulting activities.
Failure of a Member to disclose and resolve or avoid an apparent Conflict of Interest or Conflict of Commitment in accordance with this Policy, or to comply with the consulting policies referenced in the preceding paragraph, may result in administrative actions in accordance with University policies found in The Faculty Manual and the University Policies web site, in addition to any legal penalties under state and federal laws that may be appropriate. Such administrative actions may include oral admonishment, written reprimand, reassignment, demotion, suspension, or separation.
Members of the University are expected to use good judgment, professional commitment, and highest standards of ethics and integrity to protect themselves and the University from conflicts. Any Member having questions about policy or practice regarding Conflicts of Interest or Conflicts of Commitment should inquire with his/her supervisor, director, dean, department chairperson, vice president, or senior vice president or the Conflicts of Interests Administrator.
In addition to this policy, Principal Investigators and others involved in Sponsored Programs may be required to complete and submit a Financial Disclosure Questionnaire to the Vice-President for Research in compliance with the policy on Conflict of Interest and Commitment for Principal Investigators and Senior Personnel on Sponsored Programs.
This Policy may be amended from time to time pursuant to the University’s policies and procedures in effect for amending documents setting forth University policy.
- The “University” includes Syracuse University and any organization affiliated with Syracuse University, including without limitation Drumlins, Inc., Syracuse University Hotel & Conference Center, LLC, Syracuse University Press, Inc., Syracuse University Alumni Association, Inc., and S.U. Theatre Corp.
- “Family” includes (i) a spouse, domestic partner, or fiancé(e); (ii) a child, grandchild, parent, grandparent, sibling, uncle, aunt, nephew, or niece, or the spouse, domestic partner, or fiancé(e) of any such person; (iii) a person having a step-relationship described in (ii) above; (iv) a parent-in-law or a brother- or sister-in-law; (v) any other person who resides in the same household as the Employee; or (vi) any other person as to whom it would reasonably appear that the Employee has a relationship involving an interest in such person comparable to the preceding.
- “Gifts” means goods, services or anything else of value (for example, tickets, meals or product samples) furnished without charge or at a cost less than fair market value, other than items not exceeding $100 in value in any one instance or $250 in value in the aggregate during any 12 month period from a single source (or group of related sources).
- “Business Dealings with the University” means the provision of goods, services or anything else of value to, or receipt of such items from, the University other than on a non-compensated basis; provided, however, that an enrolled student shall not be deemed to have “Business Dealings with the University” solely by virtue of his or her matriculation.
Syracuse University Start-Up NY Conflict of Interest Guidelines
Syracuse University as and for its conflict of interest guidelines with respect to all matters related to the Start-Up NY program, as such program may be amended, modified, renamed, or otherwise revised from time to time, adopts each and all of the following (collectively, the “Guidelines”):
- As a general principle, service as an official of the University (a) shall not be used as a means for private benefit or inurement for the official, a relative thereof, or any entity in which the official, or relative thereof, has a business interest; (b) no official who is a vendor or employee of a vendor of goods or services to the University or who has a business interest in such vendor, or whose relative has a business interest in such vendor, shall vote on, or participate in the administration by the University of any transaction with such vendor; and (c) upon becoming aware of an actual or potential conflict of interest, an official shall advise the Chancellor and President of the University of his or her or relative’s business interest in any such existing or proposed vendor with the University.
- The University shall maintain a written record of all disclosures of actual or potential conflicts of interest made pursuant to “1(c)” and shall report such disclosures on a calendar year basis, by January 31st of each year, to the auditor for the University. The auditor shall forward such reports to the Commissioner of the New York State Department of Economic Development, who shall make public such reports.
- For purposes of the Guidelines: (a) an official of the University has a “business interest” in an entity if the individual: (i) owns or controls ten percent (10%) or more of the stock of the entity (or one percent (1%) in the case of an entity the stock of which is regularly traded on an established securities exchange); or (ii) serves as an officer, director, or partner of the entity; (b) a “relative” of an official of the University means any person living in the same household as the individual and any person who is a direct descendant of that individual’s grandparents or the spouse of such descendant; and (c) an “official” of the University means an employee at the level of dean and above, any members of the Board of Trustees, as well as any other person with decision-making authority over the Start UP NY program.
- Secretary to the Board of Trustees (COI coordinator and member of the Board of Trustees) for Council members, corporate officers and selected other employees
- Director of Tax Reporting, Office of the Comptroller COI Administrator for all other employees and for post-audit of annual COI reporting process
Links to Procedures and Related Information
- Faculty Manual
- Conflict of Interest for Principal Investigators
- Outside Professional Consulting by Non-Faculty Employees
Date: November 2002
Amended: December 2010
Amended: December 2014