3.1.2.1: University Transactions

As soon as an employee receives knowledge of a University transaction or proposed University transaction:

1. To which such employee or a member of the employee’s immediate family is a party, regardless of the dollar amount of the transaction, or

2. With an organization in which such employee or a member of the employee’s immediate family has a financial interest and in which the amount involved in the transaction exceeds or is likely to exceed $500.

Such employee shall disclose the nature of the employee’s or the employee’s family member’s interest in the transaction. All disclosures required under this policy shall be directed in writing to the Vice President or senior administrator in charge of the business area in which the employee works and the Corporate General Counsel. Prompt review of the proposed transaction shall take place in order to determine whether a conflict exists and whether the conflict must be eliminated or addressed in some way.