Conflict of Interest refers to situations in which financial or other benefit considerations may compromise or have the appearance of compromising, an employee’s or representative’s professional judgment in conducting their duties and responsibilities to the University. Conflicts of interest occur when a University employee, or representative, or their business, if any, their immediate family member(s), or their close personal friend(s) directly or indirectly benefit financially or otherwise from the employee’s, or representative’s position with the University when the benefit does or could influence the employee’s or representative’s judgment inappropriately, or could compromise the employee’s or representative’s ability to carry out his/her duties and responsibilities for the University or could be a detriment to the University’s integrity or financial results.

Northwood employees must complete and sign this form (whether or not an apparent or real conflict of interest may exist) and deliver it to the University’s Human Resources Department; this form must be submitted on an annual basis, and amended whenever there is a material change in the information presented in the information or statements included in the form.

Questions about an external activity representing a conflict of interest should be referred to the University’s Human Resources Department (989) 837-4345 or .

Employees of Northwood University represent the University by their dedication to the school and its philosophy. Employees must remember that their activities outside the University are representative of Northwood University as an educational institution and should, therefore, reflect good judgment and decorum.

Community service, as well as active association in professional organizations, clubs, and consulting activities is encouraged. However, employees must not conduct such activities on Northwood University time unless previously approved by their immediate manager.

Each employee must avoid incurring any kind of financial or personal obligation which might affect his judgment in dealing for the University with outside firms or individuals. Employees must examine their own activities and those of their families to be sure that no condition exists which create a conflict of interest or apparent conflict of interest with respect to transactions of the University.

Scope

The University respects the rights of its employees regarding their employment. The University also respects the employees outside activities, which are private in nature and in no way should conflict with or reflect negatively upon the University. The University believes employees have been carefully selected and trusts their integrity, judgment and professionalism. A conflict of interest exists when a Board member, officer, staff or faculty member has an outside interest that has the potential of being at variance with the best interests of the institution.

Examples include:

1. Conflicting financial interests
2. Use of confidential information for personal gain
3. Unauthorized disclosure of confidential information
4. Use of institutional time and facilities for personal purpose, or other activities

It is also recognized that the appearance of a conflict of interest when, in fact, it may not exist, can be damaging to the institution.

Policy

1. There are certain areas in which each individual must be concerned. Where there is any question about a conflict of interest, even though it may not exist in actuality, the particular situation should be disclosed in writing and filed with the Human Resources Department and the individual’s manager. The areas about which care should be exercised include the following:
   1. Holding a financial interest of 5% or greater (including stockholder, partner, joint venture, creditor, guarantor, or director) in a firm which provides services or supplies, materials, or equipment to the University.
   2. Borrowing money from suppliers, individuals or firms with whom the University does business except for financial institutions.
   3. Accepting gifts or favors for oneself or for any member of one’s immediate family, or entertainment or other personal obligations, from an outside organization or individual which are substantial enough to influence one’s selection of goods and services for the University. This does not apply to acceptance of perishable or consumable gifts of a nominal value of $50 or less, nor reasonable personal entertainment, but care must be exercised to be sure that continuation of such matters does not gradually build up into an embarrassing obligation. In the case of gifts that are of a substantial nature, these should be returned to the donor with explanation that University policy does not permit the acceptance of the gift. The University will take care of the expenses of returning such gifts.
   4. The misuse or unauthorized release of information to which the employee has access by reason of his position, such as the disclosure of confidential information to competitors or others outside the University.
   5. Outside employment should be approved by the employee’s manager and Human Resources should be notified.
   6. The holding of any security not exceeding 1% of any class of security of a publicly- traded corporation will not be deemed a violation of this policy.
2. Employees are encouraged to foster wholesome and appropriate relationships with colleagues, students and staff. It will be considered misconduct if you are, or could be in a position to evaluate or manage any enrolled student or employee of the university with whom you have a personal relationship or to whom you are related by blood, law or marriage. It will be considered misconduct for a Northwood University employee to engage in sexual activity with any enrolled student of the university, other than his/her spouse.

Disclosure

Statement for Apparent or Real Conflicts of Interest: Conflict of Interest refers to situations in which financial or other benefit considerations may compromise or have the appearance of compromising, an employee’s or representative’s professional judgment in conducting their duties and responsibilities to the University.

Conflicts of interest occur when a University employee, or representative, or their business, if any, their immediate family member(s), or their close personal friend(s) directly or indirectly benefit financially or otherwise from the employee’s, or representative’s position with the University when the benefit does or could influence the employee’s or representative’s judgment inappropriately, or could compromise the employee’s or representative’s ability to carry out his/her duties and responsibilities for the University or could be a detriment to the University’s integrity or financial results.

Statement

I have received and read the policy on “Conflict of Interest” and am not aware of any real or potential violation of this policy, except as noted below. In the event an unforeseen conflict of interest develops, I will report this to the President. With regard to such matters in which there is a conflict of interest, I will refrain from acting on any such matter on behalf of the University without the involvement of other disinterested persons who shall make any necessary decisions on behalf of the University with reference to such matters. I will not take unfair advantage of any information which may have come to my attention in my role as an employee of the University, and I will avoid any attempt to influence the handling of such a matter so as to give me an unfair advantage because I am a University employee.

I further recognize that because of my responsibilities in the administration of Title IV funds, there is a greater element of care and responsibility. I recognize that a conflict of interest may arise because of responsibilities and positions beyond those connected to Northwood University and have disclosed potential conflicts below.

I further declare that I have not been convicted of any violation of federal law and especially those laws dealing with Title IV funds. I further agree to report to Northwood University if at any time I am investigated or convicted of a violation of any federal laws, state laws including, but not limited to, those dealing with Title IV funds or financial aid awarded to Northwood or other students.

Disclosure

Scope

Full-time employees’ primary work obligation is to Northwood University. Maintaining outside employment is discouraged. If a full-time employee maintains an outside job, this job will not interfere with the employee’s normal work hours or performance. Part-time employees may maintain outside employment but the outside job should not interfere with the employees’ normal work hours or performance at Northwood University.

Policy

1. Prior to accepting an outside position, full-time employees must consult their immediate manager to discuss potential conflicts of interest and obtain approval.
2. The employees’ manager must notify the Human Resources Department/Representative prior to approving outside employment requests.
3. Manager must have employee complete a Conflict of Interest form to be forwarded to the Human Resources Department/ Representative for approvals and inclusion in the employees’ personnel file.
4. Both full-time and part-time employees must disclose outside employment on Conflict of Interest form upon hire or upon commencement of outside employment and annually when Conflict of Interest form is distributed to all employees.

Disclosure

Policy

Application for employment of close family relatives will be considered with other qualified applications when personnel vacancies occur. Some restrictions in job placement will apply to prevent problems of supervision, safety, security and morale. “Close family relatives” include spouse, children, parents, grandparents, siblings, in-laws and step family members.

Definitions

1. Close Family Relatives: For the purpose of this policy, “close family relative” shall include: parents, parents-in-law, spouse, child, step-child, son-in-law, daughter-in-law, brother, brother-in-law, sister, sister-in-law, grandparent, grandchild, and any other relative residing in the employees’ household.
2. New Employees: The employment of a new employee which would violate the General Policy is prohibited.
3. Current Employees: The President will review each case of promotion, transfer, marriage, etc., of current employees which results in a violation of the General Policy to determine whether:
   1. The transfer, promotion, etc., will be denied.
   2. Reassignment or transfer is necessary. Reassignment will be made at the earliest possible opportunity.

Disclosure