Office of Origin: Human Resources
Responsibility: Executive Director, Human Resources
Date Adopted: 04-27-99
Dates Reviewed: 03-13-09, 07-14-18, 3-29-22
Last Date Board Approved: 3-29-22

Lake Michigan College (the College) strives to protect the College from conflicts of interest.  

A conflict of interest occurs when an employee’s personal interests – family, friendships, financial, or social factors – do, could, or could appear to compromise their judgment, decisions, or actions in the workplace. In other words, a conflict of interest exists when an employee has or appears to have the opportunity to influence decisions in a way that could lead to personal gain or give improper advantage to:

• themselves, 
• any member of their immediate family, 
• their partner, 
• any entity in which the employee possesses a material interest (i.e., more than 1% ownership), including an organization which employs or is about to employ the employee, any member of their immediate family, or their partner.

The above is collectively known as “Interested Parties.”

Employees must avoid situations in which associations and interests could compromise or reasonably appear to compromise College business decisions. Accordingly, it is the policy of the College that each employee act in a manner consistent with their responsibilities to the College and make full disclosure of any relationship, action, position, or interest that is in or appears to be in conflict with their duties as an employee and College fiduciary.

Employees are required to familiarize themselves with and abide by this policy. All employees must complete a Conflict of Interest Disclosure Form at the time of hire and provide to Human Resources (HR); the form must be updated and provided to HR as changes warrant.   

Employees are expected to disclose to their supervising Cabinet member any actual or perceived conflicts of interest. The supervising Cabinet member, in consultation with the President, may authorize exceptions.

Violation of this policy may lead to disciplinary procedures, up to and including suspension, discharge, dismissal, termination, expulsion, and/or legal action.

Examples of Conflicts of Interest

The following may cause or give the appearance of a conflict of interest and are described to assist employees in remaining in compliance with this policy. It is impossible to describe all situations; therefore, the prohibitions included are not an exhaustive list.

1. Misuse of Confidential Information
   Employees are not to disclose confidential or proprietary information to anyone either inside or outside the College who does not have the authority to possess such information.
2. Political Use of College Funds
   Authorizing the use of College resources, whether directly or indirectly, for the use or benefit of and/or for the purpose of supporting or opposing, any political party, candidate, committee, interest, or government or subdivision thereof is prohibited.
3. Political Campaigning on Campus
   Employees may not campaign on College property to promote personal political issues or candidates for local, state, or national office while performing their employment or during normal work time.
4. Use of Family Members
   Using family members to perform acts of conflict of interest on the employee’s behalf is prohibited.
5. Providing  Goods or Services to the College
   No employee may furnish goods or services to the College or its agents, employees, or subcontractors for compensation except under such terms and conditions as are made available to the public in the general course of business. Employees are not precluded from donating goods or services to the College. 
6. Award of College Contracts
   Employees may not participate in, evaluate, or recommend the award of any contractor benefit to an Interested Parties.
7. Acceptance of Goods or Services Provided by College
   Employees or Interested Parties who receive, obtain or use goods or services from the College will pay fair consideration in amounts as paid by members of the public in general, and will adhere to the ordinary College policies and procedures. 
8. Sale or Lease of Land / Property to the College
   No employee or Interested Parties may enter into a sale or lease to the College unless full disclosure of the relationship has been made to and approved by the President.
9. Supplemental Employment
   A full- or part-time employee (other than part-time faculty) may engage in outside employment provided that the following are observed. If there is any question of a conflict of interest, the employee should notify their immediate supervisor prior to engaging in the supplemental employment.
   1. The employment does not interfere with the employee’s responsibilities to the College.
   2. The employee does not represent that their outside employment is in any way connected with their position at the College, or with the College itself, or that they are acting as an agent, representative, or employee of the College. Where appropriate, the employee must make affirmative disclaimers of any such connections.
   3. The employee does not use College equipment, materials, or services in connection with their outside employment.
   4. If an employee’s supplemental employment interferes with job performance, the employee may be requested to end or modify the supplemental employment as a condition of continued employment by the College. 
10. Non-Compete Clause
    No full-time employee may receive financial or other remuneration for providing goods or services to the public within the College’s taxing district that are provided by the College or for which the employee has been hired by the College to provide to the taxing district. If it is not clear if the College is engaged in the sale of a good/service for which an employee may be remunerated, the employee should consult with their supervising Cabinet member. 
11. Incompatible Outside Employment
    No full-time employee may engage in outside employment when that employment is incompatible or in conflict with the discharge of their College duties, or when employment may impair their independence of judgment or action in the performance of their College duties.
12. Personal Consulting/Speaking Engagements
    Employees who engage in personal consulting work or speaking engagements will not represent that they are rendering such on behalf of the College, or in any other way acting in an official capacity with the College, unless authorized in writing by their supervising Cabinet member or the President.
13. Presentations and Public Addresses
    When acting as a spokesperson for the College, providing public addresses, and/or presenting during working hours, an employee may not accept a fee, salary, honorarium, or other compensation. Reasonable reimbursement for travel, lodging, meals, or nominal courtesies may be accepted.
14. Personal Opinion
    An employee may not represent their personal opinion as that of the College.
15. Supplemental Work at College
    Employees may undertake supplemental work with the College for extra compensation only if the supplemental work does not interfere with the employee's primary assignment. All supplemental work for with College must be approved in writing by the employee’s immediate supervisor and Human Resources.
16. Acceptance of Gifts
    See Receipt of Gifts & Gratuities policy. 
17. Solicitation of Funds or Gifts
    Employees may not solicit, directly or indirectly, for oneself or for the benefit of Interested Parties any gift or favor from an organization with which the College does business or that seeks to do business with the College.  
18. Solicitation on Behalf of Foundation
    Solicitation of funds or gifts by employees for the benefit of the College, or any College group or organization, may be made only with the approval of the Lake Michigan College Foundation. 
19. Contributions to the College or External Organizations
    Employees will not be unduly influenced to contribute funds or gifts for the benefit of a group or organization external to the College or to the College itself. 

References:
Receipt of Gifts & Gratuities policy
Purchasing policy
Intellectual/Proprietary Property Rights policy
Teaching by Staff policy

Conflict of Interest Disclosure Form

The following questions are to be answered by all employees.
1.    Do you have knowledge of any proposed action which may place you in conflict with the Conflict of Interest – Employee policy? 
NO______________YES_______________ 
If yes, please explain full details below.

2.    Are you a director, employee, or agent of any entity, which, during the performance of your duties with that entity, might place you in a position of being out of compliance with the Conflict of Interest – Employee policy? 
NO_____________YES________________
If yes, please list the entity by name below.

3.    Do you or any member of your immediate family own an interest of more than 1% percent in any entity identified as doing business with the College?
NO______________YES_______________ 
If yes, please list the entity by name below.

Name: _____________________________________________________________________

Signature:__________________________________________________________________

Date: _______________________________________________________________________