University Policies & Forms
- Employee Handbook
- A-Z Index of University Policies
- Ethics Reporting Hotline
- Guiding Principles of Conduct
- Financial Forms
Conflict of Interest and Gift & Gratuities Policy for all members of the University Executive Council
Applicability of Policies
These policies apply to all members of the University Executive Council and are being considered for all full-time employees and part-time non-student employees.
Pace University employees have an obligation to avoid activities or situations that may result in a conflict of interest or the appearance of a conflict of interest. They must not use their University positions to influence outside organizations or individuals for the direct financial, personal, or professional benefit of themselves, members of their families, or others with whom there is a personal relationship.
University employees may not obtain for themselves, or any person with whom they have a personal or business relationship, a material interest of any kind from their association with the University other than compensation received as a member of the faculty, staff or administration.
If a University employee has a potential interest in a proposed transaction with the University in the form of a significant personal financial interest in the transaction or in any organization involved in the transaction, or holds a position as trustee, director, or officer in any such organization, he or she must make full disclosure of such interest before any discussion or negotiation of such transaction. Such disclosure shall be made with respect to the President, to the Chairman of the Board of Trustees, with respect to other University Officers, to the President, with respect to Deans, to the Provost and the President, with respect to Department Chairs, to School’s Dean and the Provost, with respect to other employees, to the Vice President who is in charge of the employee’s administrative unit.
University employees shall not accept employment outside the University (including outside consulting) or serve as an officer or director\trustee of another entity if it interferes with satisfactory job performance in a University position, or if there is a conflict of interest or the appearance of a conflict of interest as a result of such outside employment or service as an officer or director\trustee. Permission to engage in outside employment or to serve as an officer or director\trustee of another entity must be obtained in advance, with respect to the President, from the Chairman of the Board of Trustees, with respect to other University Officers, from the President, with respect to Deans, from the Provost and the President, with respect to Department Chairs and faculty, from the School’s Dean and the Provost, and with respect to other employees, from the Dean or Vice President who is in charge of the employee’s administrative unit.
The potential for conflict of interest exists across a wide range of activities in all areas of the University. Circumstances surrounding actions and decisions may be complex, and judgments on whether a conflict exists may be difficult to make.
University employees have an affirmative obligation to examine carefully any situation where there is potential for conflict of interest or the appearance of conflict of interest. Failure to do so may result in disciplinary action. University employees who are concerned that a conflict may exist, or who are uncertain as to the effect or appearance of their activities, must, consult with the appropriate University official prior to engaging in such activity. The President shall consult with the Chairman of the Board of Trustees; other University Officers shall consult with the President; Deans shall consult with the Provost and the President; Department Chairs and faculty shall consult with the School’s Dean and the Provost; and other employees shall consult with the Dean or Vice President who is in charge of the employee’s administrative unit.
Gifts and Gratuities Policy
University employees are prohibited from soliciting or accepting cash gifts or gratuities of any amount from any person or entity doing (or proposing to do) business with the University. Furthermore, unless specifically excepted by this policy, University employees are also prohibited from accepting non-cash gifts of any type, including materials, services, travel, and attendance at a charitable or similar event as a guest and entertainment at no cost or at unreasonably discounted prices from persons or entities doing (or proposing to do) business with the University. Excepted from this prohibition are usual and customary:
- holiday business gifts of a value of not more than $75 for the shared use of department personnel;
- occasional meals in connection with University business meetings and events and University sponsored or pre-approved charitable or similar events;
- review copies of vendor provided textbooks and other teaching related materials; and
- ceremonial gifts received by University employees in the course of official business. Such ceremonial gifts are the property of the University.
All unpermitted gifts must be immediately declined, returned or discarded. Employees must report to their supervisors and the Vice President for Human Resources at the end of each month regarding all gifts received during the month (including those permitted by this policy). Notice of this Gifts and Gratuities Policy will be given to all University vendors and prospective vendors (Form to be developed). Any proposed exceptions from this policy must be approved in advance, with respect to the President, by the Chairman of the Board of Trustees, with respect to other University Officers, by the President, with respect to Deans, by the Provost and the President, with respect to Department Chairs and faculty, by the School’s Dean and the Provost, and with respect to other employees, by the Dean or Vice President who is in charge of the employee’s administrative unit. If you have any question concerning this policy, consult with the University Counsel.