St. Lawrence University: Policies

Code of Conduct and Conflict of Interest Policy
for Senior Financial Managers

This code outlines the expectations or standards of conduct for St. Lawrence University employees with significant responsibilities related to the financial assets of the university. Senior Financial Managers include the President,all vice presidents and many management staff. Each of these managers shall acknowledge receipt and understanding of this policy and complete the Conflict of Interest Statement.

These employees should:

• Conduct themselves in an honest and ethical manner, including the ethical handling of actual or apparent conflict of interest between personal and professional relationships. Each senior financial manager should execute a Conflict of Interest Statement and update it annually.

• Strive for full, accurate, timely and understandable disclosure in reporting of financial activity and results.

• Ensure, to the best of their ability, that their work and actions comply with applicable government laws, rules and regulations.

• Proactively promote ethical behavior among subordinates and peers and encourage employees to act responsibly, with due care, without misrepresenting or omitting material facts or allowing independent judgment to be compromised.

• Promptly report violations of this code to their respective Vice President, the President of the University or the Chair of the University’s Audit Committee of the Board of Trustees. Confidentiality of individuals reporting violations of these standards will be maintained whenever possible. Retaliation against individuals reporting a violation or a potential violation of this policy will not be tolerated.

Code of Conduct for Senior Financial Managers

I _________________________________, acknowledge receipt and understanding of the Code of Conduct for Senior Financial Managers.

__________________________________ Date_____________
Signature

ST. LAWRENCE UNIVERSITY
CONFLICT OF INTEREST STATEMENT

__________________________________________________________________
(Print Name)

1. To your knowledge, are you an officer or director of any private sector (profit or non-profit) organization with which St. Lawrence University has business dealings?

Yes ________ No ________

If the answer to the foregoing question is “yes,” please list the names of such corporations, the office held, and the approximate dollar amount of business involved with St. Lawrence University during the preceding calendar year.
__________________________________________________________________

__________________________________________________________________

2. To your knowledge, do you, or does any member of your family, (defined as yourself, your spouse, minor children or other person living in your household) have a significant financial interest in, or receive any remuneration or significant income from, any private sector (profit or non-profit) organization with which St. Lawrence University has business dealings?

Yes ________ No ________

If the answer to the foregoing question is “yes,” please list the business organization in which such interest is held and the person(s) by whom such interest is held.
__________________________________________________________________

__________________________________________________________________

Nature and amount of each such financial interest, remuneration, or income:
__________________________________________________________________

__________________________________________________________________

3. To your knowledge, did you, or any member of your family, (defined as yourself, your spouse, minor children or other person living in your household) receive during the preceding calendar year, any gifts or loans from any private sector (profit or non-profit) organization with which St. Lawrence University has significant business dealings?

Yes ________ No ________

If the answer to the foregoing question is “yes,” list such gifts or loans as follows:

Name of Source Item Approximate Value
__________________________________________________________________

__________________________________________________________________

I affirm that, to the best of my knowledge, the foregoing information is true and complete.

________________________________________________ __________________
Signature Date

CC: Personnel File

Conflicts of Interest

An employee shall be considered to have a conflict of interest if such employee, or any member of his or her family, (defined as the employee, employee’s spouse, minor children or other person living in the household) has existing or potential financial or other interests which might impair, or reasonably appear to impair, the employee’s independent, unbiased judgment in discharge of his or her responsibilities to the University. All employees shall disclose to their division Vice President any possible conflict of interest at the earliest practicable time. No employee shall play a role in any decision in which such employee has a conflict of interest.

Updated October 2011

Policies Page	Code of Conduct and Conflict of Interest Policy for Senior Financial Managers This code outlines the expectations or standards of conduct for St. Lawrence University employees with significant responsibilities related to the financial assets of the university. Senior Financial Managers include the President,all vice presidents and many management staff. Each of these managers shall acknowledge receipt and understanding of this policy and complete the Conflict of Interest Statement. These employees should: • Conduct themselves in an honest and ethical manner, including the ethical handling of actual or apparent conflict of interest between personal and professional relationships. Each senior financial manager should execute a Conflict of Interest Statement and update it annually. • Strive for full, accurate, timely and understandable disclosure in reporting of financial activity and results. • Ensure, to the best of their ability, that their work and actions comply with applicable government laws, rules and regulations. • Proactively promote ethical behavior among subordinates and peers and encourage employees to act responsibly, with due care, without misrepresenting or omitting material facts or allowing independent judgment to be compromised. • Promptly report violations of this code to their respective Vice President, the President of the University or the Chair of the University’s Audit Committee of the Board of Trustees. Confidentiality of individuals reporting violations of these standards will be maintained whenever possible. Retaliation against individuals reporting a violation or a potential violation of this policy will not be tolerated. Code of Conduct for Senior Financial Managers I _________________________________, acknowledge receipt and understanding of the Code of Conduct for Senior Financial Managers. __________________________________ Date_____________ Signature ST. LAWRENCE UNIVERSITY CONFLICT OF INTEREST STATEMENT __________________________________________________________________ (Print Name) 1. To your knowledge, are you an officer or director of any private sector (profit or non-profit) organization with which St. Lawrence University has business dealings? Yes ________ No ________ If the answer to the foregoing question is “yes,” please list the names of such corporations, the office held, and the approximate dollar amount of business involved with St. Lawrence University during the preceding calendar year. __________________________________________________________________ __________________________________________________________________ 2. To your knowledge, do you, or does any member of your family, (defined as yourself, your spouse, minor children or other person living in your household) have a significant financial interest in, or receive any remuneration or significant income from, any private sector (profit or non-profit) organization with which St. Lawrence University has business dealings? Yes ________ No ________ If the answer to the foregoing question is “yes,” please list the business organization in which such interest is held and the person(s) by whom such interest is held. __________________________________________________________________ __________________________________________________________________ Nature and amount of each such financial interest, remuneration, or income: __________________________________________________________________ __________________________________________________________________ 3. To your knowledge, did you, or any member of your family, (defined as yourself, your spouse, minor children or other person living in your household) receive during the preceding calendar year, any gifts or loans from any private sector (profit or non-profit) organization with which St. Lawrence University has significant business dealings? Yes ________ No ________ If the answer to the foregoing question is “yes,” list such gifts or loans as follows: Name of Source Item Approximate Value __________________________________________________________________ __________________________________________________________________ I affirm that, to the best of my knowledge, the foregoing information is true and complete. ________________________________________________ __________________ Signature Date CC: Personnel File Conflicts of Interest An employee shall be considered to have a conflict of interest if such employee, or any member of his or her family, (defined as the employee, employee’s spouse, minor children or other person living in the household) has existing or potential financial or other interests which might impair, or reasonably appear to impair, the employee’s independent, unbiased judgment in discharge of his or her responsibilities to the University. All employees shall disclose to their division Vice President any possible conflict of interest at the earliest practicable time. No employee shall play a role in any decision in which such employee has a conflict of interest. Updated October 2011
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