4
d. If there is any question whatsoever about an external activity representing a
conflict of interest, then the employee should consult with his or her supervisor
for directions. If the employee’s supervisor is not available within a reasonable
period of time, then the employee should contact the associated unit head for
directions.
g. Unit head responsibilities
a. Unit heads shall ensure that all new employees are informed of this policy.
b. Unit heads shall ensure that all current employees are reminded of this policy on a
periodic basis, but no less frequently than annually.
c. Unit heads shall evaluate and manage reported conflicts of interest.
d. In the event that a reported conflict of interest is approved, the unit head shall
ensure there is an appropriate management strategy in place to assure that no
employee is directly or indirectly involved in making a decision where that
employee has a conflict of interest.
e. Unit heads shall ensure that Conflicts of Interest Disclosure forms are retained for
future reference. Upon an employee’s transfer from the unit or termination from
the university, associated Conflict of Interest forms shall be forwarded to the
campus HR office, for inclusion in the employee’s official personnel file. All
information disclosed regarding conflicts of interest shall be considered part of
the employee’s personnel file and shall be deemed confidential. Any information
disclosed by an employee as required by this policy shall be used solely for the
purpose of administering this policy and shall not be used for any other purpose
unless required by law.
f. Unit heads shall establish and maintain a work environment that encourages
employees to ask questions about real or potential conflicts of interest.
g. If the unit head has any question whatsoever about an external activity
representing a conflict of interest, then he or she should consult with the next
higher level of university management.
Definitions
1. Conflicts of interest occur when an employee or an employee’s relative receives personal
financial benefit from the employee’s university position.
2. External activity means involvement with any person, trust, organization, enterprise,
government agency, or other entity that is not an entity associated with or under the
control of Tuskegee University.
3. Relative includes a current or former spouse; domestic partner; or (whether by blood
adoption, “step-” half-, or foster relationship, marriage, legal action or domestic
partnership, (including in-laws), the child, parent, grandparent, sibling, grandchild,
cousin, aunt or uncle, niece or nephew, or any person in a romantic or consensual sexual
relationship or residing (or previously residing) in the immediate household (or the
household of the spouse or domestic partner of any of these relatives) of the University
employee or his or her spouse or domestic partner, or person in a romantic relationship.
4. Manage and managing means an affirmative action by supervisors and managers to
monitor and direct an employee with regards to specific expectations.