Consistent with its mission of service and its desire to operate openly, fairly, and for the common good, employees of Heritage University are expected to maintain high ethical standards and exercise sound business judgment in carrying out their duties and responsibilities.

In addition, employees of Heritage University shall not maintain any financial interests, direct or indirect; engage in any business or transactions; use privileged information or personal influence; nor undertake any activity that will secure any individual or group special privileges or advantages that are in conflict with their obligations or responsibilities to the University.

Employees must disclose any circumstances they become aware of that may constitute a conflict of interest, including all circumstances where the appearance of a conflict may be inferred by others not party to the transaction.

Examples of circumstances that may constitute a conflict of interest include:

* accepting a personal gift or service worth more than $50 or which may influence or appear to influence a decision, regardless of value.

* an outside interest on your part, a close member of your family's part, or a personal associate's part in a business supplying goods or services to the University.

* serving as an employee or agent of organizations that provide services similar to those offered by the University.

* the personal use of University facilities or supplies for non-University purposes.

It is the employee's responsibility to disclose to the appropriate Cabinet Officer any potential conflict of interest whether it involves them or others. Employees are expected to recuse themselves from any involvement in matters where a conflict of interest may exist, pending evaluation of the potential conflict of interest by the appropriate administrator. Failure to disclose conflicts of interest will be grounds for disciplinary action.

The University will be responsible for orienting all new employees on this conflict of interest policy and will require designated employees to receive an annual orientation on conflicts of interest.

Certain Granting Organizations including, but not limited to the National Science Foundation and US Department of Health and Human Services, may require more restrictive disclosure measures. In such cases, investigators (grantees) will be required to provide to the Vice President for Support Services/CFO a financial disclosure statement. If a conflict exists that cannot be resolved to the satisfaction of the University, the Vice President for Support Services/CFO will notify the granting agency.