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Conflict of Interest - Employees

All members of the Guilford College community share a responsibility to serve as stewards of the resources and traditions of the College. Therefore, consistent with our values and legal obligations, the College requires all employees to perform their duties in good faith, with reasonable care, and in the best interests of the College. To that end, employees must not allow personal affiliations or interests to interfere with decisions they may make, or have influence over, regarding the business and operations of the College,  to use their authority as a College employee for personal gain at the expense of the College, or to engage in outside activities that directly compete with the College.

Purpose/Reason for Policy:  This policy is intended to:

  • identify and address potential, actual and perceived conflicts of interest (where employees could potentially benefit personally from College business transactions or where employees’ efforts on behalf of themselves or another person or entity conflict with their role as a Guilford employee). 
  • increase the College community’s awareness in order to identify potential conflicts of interest.
  • establish procedures whereby such conflicts may be avoided or properly managed.

Scope/Covered Persons:  All employees of Guilford College

Definitions:  

  • Actual Conflict of Interest:  An actual conflict of interest exists where [1] an individual takes part in a decision in which he or she is unlikely to remain impartial or maintain objectivity in choosing between the interests of the College and his/her own economic or other personal interests, [2] an employee uses their authority as a College employee for personal gain, or [3]  an employee’s efforts on behalf of a competing entity runs counter to that employee’s role as a Guilford employee.
  • Potential or Perceived Conflict of Interest:  A potential or perceived conflict of interest  is a circumstance that appears to a reasonable observer to be improper, whether or not such a circumstance is an actual violation of policy or law.

The Policy:  

Any circumstance that could cast doubt, or the appearance of doubt, upon an employee's ability to act with total objectivity and in alignment with the College's interests presents a potential conflict of interest situation. Generally, a conflict of interest exists when a person is in a position both to influence a decision and to personally benefit from that decision. Employees shall use their College positions and resources only to advance the College’s interest and not to obtain personal benefits or pursue private interests.

By way of example (and not to limit the scope of the definition of actual or perceived conflicts of interest), conflicts of interest commonly arise through direct or indirect significant financial interests that an employee may have in companies or organizations that do business with Guilford College. A conflict of interest may also arise from an employee having a membership on a board of directors or board of trustees – even an advisory board, a non-paid board, or a non-profit or charitable board -- that is in conflict with the employee’s primary role at Guilford.

The types of conflicts of interests that should be reported or disclosed include, but are not limited to, the following:

  • Use of Guilford employees, facilities, equipment or services for personal gain or profit without full disclosure, permission from College official, reimbursement of cost, payment of a rental fee, etc;
  • Acceptance of consulting fees, honoraria or part-time employment that is in conflict with an employee’s professional responsibilities to the College, particularly where proprietary practices or information may be involved;
  • Guilford employees contracting with other Guilford employees to perform work for the College that is the same or similar to that performed by the employees during normal working hours. Work by College employees for the College should be completed within normal working hours or on an overtime basis. 
  • Guilford employees contracting or hiring doing business with another Guilford College employee, one’s spouse or close relative to do work for Guilford College, without prior written approval from the Chief of Staff. 
  • Guilford employees’ taking on outside employment or volunteer activities that are in conflict with their responsibilities as Guilford employees.

Employees are prohibited from using privileged information, revealing confidential data, or divulging proprietary information to those not authorized to receive the information for purposes of personal gain or for other-than-Guilford purposes; 

Outside Employment/Involvement with Other Organizations. The College recognizes that participation with other organizations can be beneficial in terms of an individual’s personal and professional development and such involvement often enhances the College’s reputation. This policy is not meant to discourage employees from participating with other non-profit organizations or engaging in other employment, as most of these activities will not create a conflict of interest. If an employee has questions or is uncertain whether involvement in another activity or organization constitutes an actual or perceived conflict of interest, the employee should discuss the case with the appropriate Cabinet member so they together can determine whether or not there is a conflict that needs to be resolved.

A College employee who engages in other employment, either for compensation or without receiving payment, must assure that such employment does not create a conflict of interest or interfere with the employee’s duties to the College.  See Outside Employment Policy.

Accepting Personal Gifts, Gratuities, or Entertainment. Employees are expected to select vendors who will provide goods and services to the College based on objective criteria, in consideration of the College's best interests. All decisions pertaining to College business are to be made solely based on the interests of the College, not based on any personal gain or potential gain to any employee or an associate of an employee. In an effort to avoid conflicts of interest, College employees may not accept personal gifts of more than nominal value from vendors or potential vendors to the College. Specifically:  

  • College employees may not accept any gift or gratuity from an individual, a vendor, a contractor, or other organization that provides goods or services to the College, or is being considered as a provider of goods or services, with a value in excess of $50.00.
  • College employees may not accept services or entertainment from vendors or potential vendors, other than acceptance of an occasional meal, tickets to a sporting or theater event, etc.
  • College employees may not solicit personal gifts, entertainment, or payment from a vendor, or potential vendor, regardless of the value of such gifts.

Employees who are given gifts of more than nominal value or who are unsure about the acceptability of a particular gift should discuss the gift with the appropriate Cabinet member,  so they together can determine whether or not there is a conflict that needs to be resolved. If it is determined that the gift received exceeds nominal value, and/or would appear to unduly influence a College decision, the goods or services received may need to be returned/rescinded.

Employment of Relatives (Nepotism). Guilford College is committed to hiring diverse, qualified candidates and to providing opportunities for career growth to employees. The College is equally committed to avoiding conflicts of interest and the appearance of favoritism and/or bias in the hiring and/or employment process. Therefore, the College does not discriminate, in favor of or against, relatives of current or former employees who apply for positions at Guilford. For additional information please refer to the Employment of Relatives Policy.  

Retaliation. Any member of the Guilford Community who reports a real or perceived conflict of interest involving a faculty or staff member is protected from retaliation under the College’s Whistleblower Policy.  

Roles and Responsibilities: 

All Guilford College employees have an obligation to act in the best interests of the College when performing their jobs. Employees should not permit outside financial interests, legal commitments, volunteer activities, or potential for personal gain to influence -- or appear to influence -- decisions they make on behalf of the College. 

All Employees are expected to voluntarily and expeditiously disclose their degree of involvement in such outside activities by consulting with the vice president of their division  before such potentially conflicted outside professional activity is undertaken.  

Supervisors and other administrators are responsible for maintaining the integrity within their respective areas of responsibility and are obliged to notify the Chief of Staff of any potential violations of the College's Conflict of Interest Policy, if informal resolutions to the conflict have not been successful.

President’s Cabinet members are responsible for receiving and considering any requests for guidance regarding conflicts of interest, advising employees accordingly, and keeping these reports confidential whenever possible. If the potential conflict involves a member of the Cabinet, reports should be directed to the Chief of Staff.

Compliance: 

Most conflicts are unintentional, and can be resolved informally with minimal disruption to the employee or to College operations.  When the College determines that a conflict of interest exists and informal means of resolution have not been successful, it reserves the right to take appropriate action to resolve the conflict. Violations of this policy may be cause for corrective action in accordance with established procedures for staff and faculty.

Other Related Policies, Regulations, Statutes and Documents

Procedures: 

Employees should promptly notify the appropriate Cabinet member in their area if any of the following apply, or appears to apply, so they together can determine whether or not there is a conflict that needs to be resolved:

  • The employee is an executive officer, director, member of a governing body, partner, or owner of any non-profit or for-profit organization or company.
  • The employee has a financial interest in an organization or company with which the College is contemplating a transaction or business relationship or has a business relationship, assuming the employee is aware of the transaction or business relationship. This includes a financial interest in any organization or company that serves as, or is being considered to serve as, a vendor, supplier, or contractor to the College.
  • The employee stands to gain financially or in other substantial ways as a result of a decision they are authorized to make on behalf of the College by virtue of their role at the College.
  • The employee is employed or volunteers in a specific capacity that is in competition with the College.

Approval Authority:  The Guilford College President

Responsible Office: Erin Brownlee Dell, Chief Of Staff, Alumni House, 336-316-2275, edell@guilford.edu

Revision History:  New Policy. Approved by President’s Cabinet 12-11-2019