Policy Statement
This policy protects Butler University’s integrity and reputation by ensuring all employees act in the institution’s best interests. This policy guides the identification, disclosure, and management of conflicts of interest and the appearance of such conflicts.
Definitions
Definition of Conflict of Interest
A conflict of interest exists when an individual’s personal, professional, financial, or other interests interfere, or appear to interfere, with their duties and responsibilities to the university. Such conflicts may compromise objectivity, decision-making, or the institution’s reputation. Conflicts of interest may arise in, but are not limited to, the following areas:
1. Financial Interests: When an individual or their immediate family has a financial interest in an entity that does business with, seeks funding from, or competes with the university.
2. Gifts and Benefits: Accepting gifts, services, or benefits that could influence decisions or create the appearance of impropriety.
3. Outside Employment or Consulting: Engaging in external work that interferes with university responsibilities or competes with the university’s interests. The Faculty Handbook provisions on outside consulting/commitments are also applicable.
4. Research Activities: Situations where personal or financial interests could compromise or appear to compromise research integrity, objectivity, or outcomes.
5. Nepotism: Favoring relatives or close associates in hiring, promotions, or other institutional decisions.
Policy Target Audience
This policy applies to all employees (faculty, staff, and student employees) involved in research or administrative roles. It also covers external contractors, consultants, and other individuals who act on behalf of the university in an official capacity.
Procedures/Implementation
Disclosure of Conflicts
All individuals covered by this policy must promptly disclose any actual, potential, or perceived conflicts of interest:
1. Employees (including student employees) must report to their supervisor, department head, or Vice President.
2. External contractors, consultants, and affiliates must report to their university sponsor.
HR will serve in an advisory capacity to assist with uniformity and consistency of policy application across campus.
Management and Resolution of Conflicts
Upon disclosure, the university will assess the situation and determine the appropriate action, which may include:
• Recusal from decision-making or supervisory roles.
• Modification of duties or responsibilities.
• Establishment of a conflict management plan.
• Prohibition of certain activities or relationships.
Failure to disclose a conflict or comply with a conflict management plan may result in disciplinary action, up to and including termination of employment or academic appointment.
Confidentiality
All disclosures will be treated confidentially to the extent possible, consistent with the need to assess and manage the conflict. Reports may be made anonymously by using EthicsPoint (http://www.ethicspoint.com) or calling 800-445-9198.
Retaliation
The University will not tolerate retaliation against anyone who reports a suspected, potential, or actual violation of this policy. Additionally, the identity of individuals providing information concerning possible violations, including fraud, will be protected to the extent appropriate and within legal limits. Any individual who threatens or engages in any retaliatory act will be subject to disciplinary action, up to and including termination of employment.