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Conflict of Interest and Commitment Procedures

Ref. No. Executive sponsor Policy steward Approval authority First approved Last reviewed Effective date Next review
42.12              
  1. Purpose
    1. This procedure outlines the steps that must be followed in disclosing a potential Conflict of Interest or Conflict of Commitment.
  1. Definitions
Term Definition
Conflict For the purposes of this Policy, Conflict may refer to any or all of Conflict of Interest, Conflict of Commitment and/or Institutional Conflict as defined herein.
Conflict of Commitment Exists where a College employee undertakes or engages in any activity or commitment, whether paid or unpaid, apart from the employee’s normal responsibilities to the College, which may:
  1. interfere with the employee's ability to effectively carry out his/her College related duties and responsibilities,
  2. compete or conflict with the mission, goals and objectives of the College; or
  3. adversely affect the reputation of the College.

Not all outside activities or business activities of College employees amount to Conflicts of Commitment. Examples of Employee Conflict of Commitment are set out in Appendix A.
Conflict of Interest Exists when a member of the College Community has or may be perceived as having the opportunity to advance or protect a Personal Interest of the member or of a person with whom the member has a family, personal, business or similar relationship. A Conflict of Interest may arise in circumstances where Personal Interests may directly or indirectly affect the member’s professional judgment in the exercise of College duties and responsibilities. Examples of Employee Conflict of Interest are set out in Appendix A.
Institutional Conflict A situation in which the College or an institution has an existing relationship with a party with which the College or the institution proposes to enter into an activity, contract, or commitment, such that an impartial observer might reasonably question whether the existing relationship might prejudice decisions of the College or institution with respect to the activity
Personal Interest Exists where one has an interest, including, but not limited to, a financial, family, or professional interest, in a decision, activity or business affair of the College.
  1. Procedure
    1. A member of the College Community must disclose a Conflict as soon as possible by completing a Declaration of Conflict Form. They may also make a verbal disclosure to the appropriate person set out in ss. 2 and 3 and seek the assistance of that person in completing the Declaration.
    2. In the case of a Conflict of Interest, the completed Declaration must be delivered to:
      1. The Director of Organizational Development in the case of Conflicts involving an employee other than the one completing the form,
      2. The AVP Student Services in the case of Conflicts involving students, or
      3. In all other cases, the person’s Manager, or any member of College Senior Leadership, including Vice Presidents, Associate Vice Presidents, Deans, Principals or Directors.
    3. In the case of Conflict of Commitment, the completed Declaration must be delivered to:
      1. The Campus Principal, or,
      2. In the case of Central Office, the appropriate senior administrator (e.g. AVP, Dean, Director) of the department.
    4. An individual is required to update any Declaration if they become aware of any relevant changes in circumstances. This may be accomplished verbally or in a written communication with the member to whom the original Declaration was delivered.
    5. The person receiving a Declaration will coordinate the College review and response to the declared Conflict. Such review and response will be carried out in a timely, fair and open manner by the College.
    6. The person receiving a Declaration may, subject to the obligation of confidentiality, discuss the situation with other members of the College in an effort to arrive at an appropriate response.
    7. The College may require an activity or decision to be placed on hold pending assessment.
    8. The College may make any of the following determinations:
      1. no Conflict exists,
      2. a Conflict exists but can be managed, through personal undertakings of the member in conflict or other means and that such management is consistent with the values of integrity and public accountability and will withstand the test of reasonable independent scrutiny, or,
      3. a Conflict is of such a nature that it cannot be managed in a manner consistent with the values of integrity and public accountability, in which case, the College may take necessary steps to eliminate the Conflict.
    9. The resolution of the Conflict is placed in the employee’s official employment file or student file as the case may be, except where the resolution results in a finding of “no Conflict” under section 3.8(a), in which case, the Declarant may opt to have all relevant records removed from their file.
  1. Procedure Supports

Declaration of Potential Conflict of Interest and/or Commitment form
42.11 Employee Conflict of Interest and Commitment Policy
42.13 Employee Conflict of Interest and/or Commitment Guidelines
42.01 Employee Code of Conduct
44.15 Employment of Relatives Procedures
42.31 Safe Disclosure Policy

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