Policies and Procedures

C0208 Conflict of Interest and Acceptance of Gifts


No employee shall solicit or accept, directly or indirectly, on behalf of himself or herself or any member of the employee's household, any gift, including but not limited to any gratuity, service, favor, food, entertainment, lodging, transportation, loan, loan guarantee or any other thing of monetary value, from any person or entity that has, or is seeking to obtain, contractual or other business or financial relations with the College.

The prohibition on accepting gifts does not apply to:

  • A gift given by a member of the employee's immediate family or by an individual if the gift is given for a non-business purpose and is motivated by a close personal friendship and not by the position of the employee;
  • Informational materials in the form of books, articles, periodicals, other written materials, audio tapes, videotapes, or other forms of communication;
  • Sample merchandise, promotional items, and appreciation tokens, if they are routinely given to customers, suppliers or potential customers or suppliers in the ordinary course of business;
  • Unsolicited tokens or awards of appreciation, honorary degrees, or bona fide awards in recognition of public service in the form of a plaque, trophy, desk item, wall memento and similar items; provided, that any such item shall not be in a form which can be readily converted to cash;
  • Circumstances where refusal of reimbursement of a gift (such as a lunch or dinner) may be awkward and contrary to the larger interests of the College; and
  • Loans from established financial institutions made in the ordinary course of business on usual and customary terms.

If an employee accepts a gift other than office supplies under these provisions, the employee must disclose to the Business Office a description of the gift, the name of the person or organization who provided the gift, and the value of the gift, if known, or its estimated value, if unknown. Disclosure must be in writing (e-mail is preferred) and be made within seven (7) calendar days of the acceptance of the gift; When it is in the best interest of the College, the Business Office may at any time restrict an employee(s) from accepting additional gifts under these provisions.


Employees shall not engage in or have a financial interest in any activity that raises a reasonable question of a conflict of interest with their duties and responsibilities as employees. "Indirect financial interest" in this case includes a substantial interest on the part of a parent, spouse, or minor child of the employee. This shall not apply to ownership of publicly traded stocks or bonds where such ownership constitutes less than two percent (2%) of the total outstanding amount of the stocks or bonds of the issuing entity.

The normal employment compensation of a spouse whose regular, ongoing employer or business has a contractual arrangement with the College shall not be considered a "benefit" to the employee, provided the contract with the College was procured without any participation, assistance or influence by the employee.

No employee, officer, or agent will participate in the selection, award, or administration of a contract if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.

Employees shall not participate in outside activities for financial remuneration wherein their staff positions are used to sell goods or services to students.


Employees who violate this policy may be subject to disciplinary action up to and including termination.

Revised June 16, 2015
Adopted March 20, 2012