VCU University Controller's Office

Conflict of Interest Policy
The following statement of policy was issued in June, 1984 and is effective from that date; for additional information contact the Office of the General Counsel.

This policy is designed to ensure that each member of the University's faculty and staff (hereinafter collectively referred to as the "employee") is aware of certain legal and personal responsibilities arising out of employment at the University. The interests of Virginia Commonwealth University must be paramount to the interests of employees acting on its behalf. This policy on conflict of interests applies to all employees, so that there will be uniform standards throughout the University.

The Commonwealth of Virginia has promulgated conflict of interests' laws that are set forth in detail in Title 2.1, Chapter 40, of the Code of Virginia. The administrative policy herein set forth is intended to supplement, not to replace, the laws and regulations of the Commonwealth of Virginia; and any requirements of exceptions in said laws or regulations are equally applicable to this policy.

1. No employee shall solicit or accept, for services normally expected from an employee, any money, benefit, or other item of material value, except compensation, reimbursement of expenses, or remuneration paid by the University or in accordance with an approved University consultation/employment policy.
2. No employee shall accept any gift, favor, or service, the natural tendency of which might be to influence them improperly in the discharge of their duties.
3. No employee shall offer or accept money or other things of value for or in consideration of obtaining employment, promotion, or privilege at the University or at any other agency of the Commonwealth.
4. No employee shall disclose or use for personal gain any confidential information that is gained or acquired in the course of employment and is unavailable to the public.
5. No employee shall purchase or acquire goods or services from the University unless such goods or services are offered for sale to the general public.
6. No employee shall solicit, accept, promise, offer, or confer upon any other person any financial or other similar benefit as consideration for their opinion, recommendation, vote or exercise of authority.
7. No employee shall accept any type of gift from a vendor in exchange for past, present, or future University business.
8. No employee shall accept travel paid for by a vendor, for any reason whatsoever, without obtaining advance written approval from the dean, director, or vice-president responsible for the area in which they are employed. Those reporting to the president must secure the president's approval.
9. No employee shall influence or attempt to influence the results of a bid for goods or services by divulging confidential information to a prospective vendor.
10. No employee shall make improper use of University facilities, equipment, tools, or other University property, for personal gain, either on or off University premises. If there is any doubt whether a particular use may be improper, it is the policy of the University to encourage prior disclosure and resolution. In addition to the requirements of this policy, the Virginia Commonwealth University Policies Concerning Outside Professional Activity and Employment, Research, Continuing Education also apply to members of the faculty.
11. No employee shall be a contractor or a subcontractor with the University, or have a personal interest, as that term is defined in the Virginia Comprehensive Conflict of Interests Act, in any contract or subcontract with the University.
12. No employee shall be a contractor or subcontractor with any Commonwealth of Virginia agency, except as may be permitted by applicable University policies on outside consulting, without first making written disclosure of this interest to the appropriate vice-president for the area in which the person is employed. Such disclosure should be made through the appropriate dean or director. In addition, employees must disclose in writing to the contracting agency their employment with Virginia Commonwealth University, and the contract may be let only after competitive bidding or negotiation or after the contracting agency has granted an appropriate exemption therefrom.

Disclosures
Employees who know, or may reasonably be expected to know, of the existence or personal interests they may have, as "personal interest" is defined in Virginia Comprehensive Conflict of Interests Act, in any transaction with the University, shall disclose in writing such interest to the appropriate dean, director, or vice-president for the area in which they are employed, and shall disqualify themselves thereafter from participating in such a transaction on behalf of the University, as well as file such additional disclosure forms as may be required by the Act.

Violations
1. Any employee found to have willfully violated this policy shall, in addition to any fine or sanction provided by law or this policy, forfeit employment with the University.
2. Employees should be aware that, in addition to the sanctions provided by this policy and under the Virginia Comprehensive Conflict of Interests Act, soliciting, accepting, offering, or conferring any financial benefit in exchange for a decision opinion, recommendation, vote, or exercise of authority may constitute the crime of bribery.
3. Any money or other item of value gained in violation of this policy shall be forfeited to the Commonwealth by the recipient.
4. The University may dismiss from employment any person who willfully fails or refuses to file any disclosure required by this policy, or who includes misleading information in any written statement required by these policies.
5. Enforcement of this policy and adjudication of its alleged violation will be consistent with existing University disciplinary procedures.