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CONFLICTS
OF INTEREST AND NEPOTISM
IDENTIFYING
POTENTIAL CONFLICT OF INTEREST AND NEPOTISM IN PERSONNEL MATTERS
[Excerpted
from a memo from Zan Johns, Interim Director of Human Resources, May
11, 1998]
Since 1972
it has been the Policy of the Board of Regents that:
University administrators,
faculty and staff shall not participate in institutional decisions
involving direct benefits such as appointments, retentions, promotions,
salaries, leaves of absence, or awards to members of their immediate
families.
The principle
of anti-nepotism shall not be used as a criterion against appointment
or employment at the University of Colorado.
Immediate
family includes spouses, children, parents, grandparents, grandchildren,
brothers, sisters, nieces, nephews, uncles, aunts, first cousins,
fathers-in-law, mothers-in-law, sons-in-law, and daughters-in-law.
The University-wide
administrative policy statement: "Procedures for Implementing Regent
Policies on Conflict of Interest and Nepotism" interprets this Regental
Policy as follows:
The thrust of
the two policies is that while there is no prohibition against relatives
working in the same department or unit, an employee may not appoint,
nor participate in the decision-making process to appoint, a relative
to a position within the University. The decision on the appointment
must be made by someone other than the relative. Once such an appointment
has been made, subsequent decisions on the salary, promotion, and
all perquisites and benefits of the employee must be made by someone
other than the relative, even though the relative may be the supervisor
to whom the employee reports.
The following are University
of Colorado at Boulder procedures implementing these Regental policies:
A. By June
30, each year, the Dean or Director of each school/college or unit,
shall forward to the Director of the Department of Human Resources,
the following:
1. Names and
relationships of relatives who work in the same department, are
paid from the same account, and/or otherwise hold appointments where
potential or actual conflict of interest in employment relationships
exist. This list is to include all employees, including hourly and
temporary employees.
2. A written
statement as to why no conflict of interest exists in each instance
where such relationship exists. A copy of this statement shall be
included in any departmental personnel file of each affected employee.
3. Where
a potential conflict of interest exists because of the employment
relationship or other factors, a written statement shall be made
delegating authority for personnel decisions regarding the affected
employee to the immediate superior of the relative in the supervisory
position. A copy of this statement shall be included in any departmental
personnel file for each affected employee.
B. The Director
of the Department of Human Resources will review all reports and discuss
with the Deans and Directors alternatives for resolving difficult
situations of actual or potential conflict of interest.
C. The Director
of the Department of Human Resources will submit an annual report
to the Boulder Chancellor no later than August 31. This report will
contain a summary of information received and recommended solutions
to actual or potential conflict of interest situations. The Chancellor
will review the report and resolve any difficult cases.
CONFLICT
OF INTEREST POLICIES AND PROCEDURES
The following
documents can be downloaded as PDF files (viewing requires the free
Acrobat
Reader):
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