UNIVERSITY OF PITTSBURGH POLICY 07-05-03

CATEGORY:             PERSONNEL

SECTION:                 Staff Performance

SUBJECT:                Conflict of Interest for University of Pittsburgh Employees

EFFECTIVE DATE:  December 14, 1994

PAGE(S):                  2

I.    SCOPE

      The following policy applies to all University of Pittsburgh employees.

II.   GENERAL PRINCIPLES

      Employees stand in a relationship of trust and confidence to the University.  They shall act

      in good faith with due regard for the best interests of the institution, and shall comply with

      the principles of conduct hereinafter set forth.

      A potential or actual conflict of interest exists when an employee's commitments and

      obligations to the University may be compromised by his/her other interests or commitments,

      especially economic, and particularly if those interests or commitments are not disclosed. 

      Although not all conflicting interests are impermissible, those involving the potential for

      self-gain or gain by a third party to whom the employee is related can serve to undermine

      the judgment or objectivity of the employee such that the primary obligation to the

      University is compromised.  Furthermore, bias or the appearance of bias may undermine

      public trust in the University.

      The University believes that full and timely disclosure by employees, pursuant to the

      requirements set forth below, will sensitize them and their supervisors to potential conflicts

      of interest and promote resolution of actual conflicts.  Even if disclosure is not explicitly

      required below, the employee should discuss with his/her supervisor any affiliation,

      interest or other matter that presents a real, apparent or potential conflict of interest.

III.  POLICY

      Disclosure of Interested Transactions

      As soon as an employee receives knowledge of a University transaction or proposed

      University transaction

            a.   to which such employee or a member of his/her immediate family is a party,

                  regardless of the dollar amount of the transaction, or

            b.   with an organization in which such employee or a member of his/her immediate

                  family has a financial interest and in which the amount involved in the transaction

                  exceeds or is likely to exceed $500,

      such employee shall disclose the nature of his/her or the family member's interest in the transaction.

      Disclosure Review Procedure

      All disclosures required under this Policy shall be directed in writing to the next higher

      administrator in the employee's supervisory line who is at least at the level of director or

      department chairperson.  Review after disclosure must take place promptly and help the

      employee determine which interests are not in conflict, which conflicting interests may be

      permissible, and which conflicting interests must be eliminated or addressed in some way.

      Any employee who disagrees with the recommendation of the reviewing administrator may

      appeal pursuant to the appeal procedures set forth in the Conflict of Interest Policy for

      Designated University of Pittsburgh Administrators and Staff (07-05-02).

      Withdrawal from Decisions

      Employees shall not exercise University decision-making authority or exert influence

      concerning any organization or transaction in which they or a family member have a

      personal interest.

      Misuse of Information

      No employee of the University shall, for personal gain or for the gain of others, use any

      information not available to the public that was obtained as a result of service to the

      University.  No employee shall personally exploit any business opportunity in which the

      employee knows or reasonably should know the University is or would be interested,

      unless the University first consents thereto in writing.

      Gifts and Favors

      No employee shall solicit or accept for personal use, or for the use of others, any gift,

      favor, loan, gratuity, reward, promise of future employment or any other thing of monetary

      value that might influence or appear to influence the judgment or conduct of the employee

      vis-a-vis University business.  Employees may accept occasional unsolicited courtesy gifts

      or favors (such as business lunches, tickets to baseball games or Christmas baskets) so

      long as the gifts or favors have a market value under $200, are customary in the industry,

      and will not influence or appear to influence the judgment or conduct of the employee

      vis-a-vis University business.  An employee may be exempted from the restrictions in this

      paragraph by his/her supervisor as to a specified gift or favor.  The exemption shall be in

      writing with a statement of the basis therefore.  Individual administrative units within the

      University may impose further restrictions on gifts or favors for employees within the unit.

      Reporting Suspected Violations

      An allegation of violations of this Policy and the basis for the allegation shall be

      communicated, confidentially and preferably (but not necessarily) in writing, to an

      administrator in the supervisory line of the alleged violator or, if that would be problematic,

      to the Internal Audit Department or the Office of General Counsel.  Measures shall be

      taken to ensure that no adverse action is taken, either directly or indirectly, against a

      complainant who makes allegations in good faith.

      Additional Disclosure Requirements for Certain Employees

      University administrators and staff who are classified as Administrator IV or V or above,

      and others who have been specifically designated by their supervisors, are subject to the

      more specific provisions of the Conflict of Interest Policy for Designated University of

      Pittsburgh Administrators and Staff (07-05-02). University faculty, researchers, and

      administrative employees who can materially influence research are also subject to the

      more specific provisions of the Conflict of Interest Policy for Faculty, Scholars,

      Researchers, Research Staff/Coordinators (11-01-03).