Effective Date: December 18, 2006

Signature/Position: Assistant Vice-President, Finance and Services

Table of Contents

SUBJECT
GENERAL
PURPOSE
SCOPE
DEFINITIONS
POLICY

SUBJECT

Conflict of interest policy (external business associations & disclosure thereof)

GENERAL

It will occasionally be in the best interests of the University to acquire goods and services from, or to give or to sell goods or services to, external organizations which have associations with the University or with certain University employees. 

PURPOSE

To ensure that, where such situations exist, the acquisitive or dispositive decision is made on an arms-length basis by employees not associated with the external organization. This will protect employees from allegations of conflict of interest and will ensure that University interests are properly represented. 

SCOPE

Officers, members of faculty, professional staff and other employees in an executive, professional, administrative, supervisory or technical capacity, or any person responsible for the approval, issuance or allocation of an order, contract, commitment or specification for material or services to be furnished by suppliers; or, any of the above-mentioned persons or person, responsible for the determination on prices or terms, for the sale of, or purchase of materials, supplies or services, to clients or from suppliers, on behalf of the University.

DEFINITIONS

"Member" includes any officer, member of the faculty and staff, professional staff and all other employees of the University.

"Immediate Family"includes spouse, common-law spouse, siblings, children, parents, in-laws, or those persons of the member's and his or her spouse's relations residing in the same household. 

"Arms Length" An employee will NOT be dealing at arms length when:

a. the University is buying or selling or giving goods or services from or to that employee or some member of his or her immediate family,

or

b. the University is dealing with an enterprise where that employee or some member of his or her immediate family has a pecuniary interest.

"Substantial" means large in amount or of considerable value in relation to normal transactions of a like activity, service or business and pertaining to the amount or value of the acts or items concerned and in any event will mean any benefit having a value in excess of $500.00.

POLICY

1. University members are prohibited from accepting substantial gifts, benefits or favours for their use or enjoyment offered from a client, supplier, proposed supplier, purchaser, proposed purchaser, donee or proposed donee, association, institution or person with whom the member is dealing on behalf of the University of Guelph or on behalf of any fund which the University holds in trust.
2. University members are prohibited from doing business or having financial dealings on behalf of the University with any enterprise with whom or with which they are not dealing at arms length. In particular:
   1. University members are prohibited from approving requisitions or payments for the purchase of goods or services from enterprises in which the member or some member of his or her immediate family has financial interest; and
   2. University members are prohibited from selling or giving or approving sales or gifts to enterprises in which the member of some member or his or her immediate family has a financial interest.
3. University members are prohibited from doing business with, having financial dealings with or receiving remuneration or substantial gifts from any supplier, purchaser or enterprise that competes or conflicts with the aims and objectives of the University.
4. Where any University member finds himself/herself in a situation which breaches, has breached or is likely to breach these guidelines; the member shall immediately disclose the matter to the immediate supervisor and to the Vice-President (Finance and Administration). The supervisor shall either take over the matter personally or shall delegate it to another employee, ensuring in the process that no further breach of this policy occurs. In each case where a breach of this policy has been reported to a supervisor, the Vice-President (Finance and Administration) shall be immediately advised in writing of the breach.