4-5: Conflict of Interest Policy – Procedures

1. Any member of the SFCC community should report a suspected conflict of interest as described in Policy 4-5 to their supervisor. If an employee believes their supervisor is engaging in a conflict of interest the employee may submit a written report or provide an oral report to the Office of Human Resources.
   1. The Office of Human Resources shall make an initial determination of whether any complaint about a conflict of interest alleges facts that may fairly be understood to constitute a conflict of interest against law or policy. If the Office of Human Resources determines the complaint does not allege such facts that may fairly be understood to constitute a conflict of interest, the Office of Human Resources shall notify the complaining party. The Office of Human Resources will maintain the confidentiality of such a complaint.
   2. If the Office of Human Resources determines that a complaint of conflict of interest alleges facts that may fairly be understood to constitute a conflict of interest, the Office of Human Resources shall immediately notify the Vice President and ascertain the action the Vice President determines is appropriate.
   3. If the Office of Human Resources substantiates allegations of a conflict of interest after investigation, they shall report the results of the investigation to the Vice President. Discipline consistent with Policy 4-2 Employee Corrective Action and Disciplinary Action, up to and including termination, may be imposed.
2. Any employee may request from their supervisor and the Office of Human Resources to consider whether a circumstance is or may lead to a conflict of interest as prohibited by Policy 4-5. The Office of Human Resources shall also consult with fiscal staff as necessary. If the employee provides all material facts to the supervisor and the Office of Human Resources, and if they determine no actual conflict or appearance of impropriety exists, the employee shall not later be determined to have a conflict of interest absent a change of facts.

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Updated:        1/26/18

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