Conflict of Interest

Division: 

Administration & Finance

Department: 

Human Resources

Contact Information: 

Praveen Rattan / Professional & Leadership Development Manager / (415) 405-3934 / prattan@sfsu.edu

Revised Date: 

Wednesday, September 6, 2017

Authority: 


Objective: 

To provide information and provisions for the adoption of Conflict of Interest.


Statement: 

The Political Reform Act of 1974 contains a general prohibition against conflicts of interest and provisions for the adoption of a Conflict of Interest (COI) Code by the California State University (CSU).

Positions that make or participate in the making of decisions which may have a foreseeable material effect on financial interests are designated under the Conflict of Interest Code and are subject to filing a Statement of Economic Interests Form 700.  Positions are designated if responsibilities include making, participating in or influencing decisions regarding:

  • The physical Master Plan of the University
  • The total enrollment of the University
  • The license, lease, purchase or sale of real property of/for the University
  • The purchase of supplies, materials, commodities, machinery, equipment, services or work for the University, school, department or area
  • The entering into/amending construction/service contracts in connection with construction contracts for the University
  • The investment of University funds

In addition to filing an annual Statement of Economic Interest Form 700 disclosing personal financial interests, employees occupying designated positions are required to complete an Ethics & Conflict of Interest training program every two years. Employees who are required to complete Ethics Training and file the Form 700, will be notified by the University Conflict of Interest Filing Officer within 30 calendar days of  appointment. Employees will then be notified annually thereafter of their filing obligation at which time employees must file a Statement of Economic Interest Form 700, which must be completed and be received in Human Resources no later than April 1 of every year.  A fine, payable to the SF State General Fund, is assessed for each day beyond the filing deadline.

Employees holding such designated positions are required to disqualify themselves when confronted with a decision-making responsibility that will have a reasonably foreseeable material financial effect on a personal financial interest.

The COI Code contains an ethics section requiring the reporting of acceptance of an honorarium or gifts in excess of a specified amount from any single source in a calendar year.  The aggregate limitation on gifts, which is biennially indexed for inflation, is $470.  Effective 2017-2018, the limit is $470 from a single source in a calendar year.  Gifts or payments to SFSU for University use may avoid problems with the ethics provisions.

While the above information provides a brief overview of COI, detailed information will be attached to your notification letter, to include a Statement of Economic Interest Form
700.   Definitions, forms and specific instructions for filing are available on the Fair Political Practices Commission website.

 

Procedures:

 

Conflict of Interest Policies, Program, Forms

http://hr.sfsu.edu/Labor_Compliance_ProfDev/emp_relations/hr_Directives/P203

 

Conflict of Interest (COI) Annual Filing Letter can be accessed at the following link:  https://csyou.calstate.edu/Policies/HRPolicies/HR2017-02.pdf

 

Links to annual filing documents included in Conflict of Interest (COI) Annual Filing Letter:

  1. CSU Disclosure Category List (Attachment A)
  2. Campus Designated Position List (Attachment B)
  3. 2016-17 Statement of Economic Interests Form 700
  4. Frequently Asked Questions:  Form 700 Disclosure
  5. 2016-17 Form 700 Statement of Economic Interests Reference Pamphlet
  6. Limitations and Restrictions on Gifts, Honoraria, Travel and Loans Fact Sheet
  7. 2016-17 Principal Investigator’s Statement of Economic Interests Form 700-U and Instructions for Statement of Economic Interests for Principal Investigators
  8. Conflict of Interest Handbook

 

Updated August 2017:

Regulations regarding gifts to agency and certain gifts of tickets and passes to event can be accessed at the following link  https://csyou.calstate.edu/Policies/HRPolicies/HR2017-08.pdf

 

Fair Political Practices Commission website:

http://www.fppc.ca.gov/