APPENDIX XVIII


POLICY ON CONFLICT OF INTEREST

I. INTRODUCTION
Consistent with the mission of the State University of New York, all faculty and staff are encouraged to pursue free and open inquiry and the unrestricted dissemination of knowledge. Open exchange of scholarly knowledge is integral to SUNY's goals of instruction, research and scholarship, and public service. Moreover, as members of a public university, the faculty and staff of SUNY have a responsibility to ensure integrity in all aspects of the performance of their assignments.
This policy represents a restatement of existing University policy and pertinent State and Federal law and regulations including:
 Policies of the Board of Trustees, Article XI, Title H, Section 4; New York State Public Officers Law, Section 73-a, and 73 and 74; 42 Code of Federal Regulations (CFR) Part 50, Subpart F; and National Science Foundation, Grant Policy Manual (GPM), Section 310

II. DEFINITION
- A conflict of interest is any interest, financial or otherwise, director indirect; participation in any business, transaction or professional activity; or incurring of any obligation of any nature, which is or appears to be in substantial conflict with the proper discharge of an employee's duties in the public interest. A conflict of interest is also any financial interest that will, or may be reasonably expected to, bias the design, conduct or reporting of sponsored research.
III. POLICY
Faculty and staff of the University are encouraged to foster an atmosphere of academic freedom by promoting the open and timely exchange of scholarly knowledge independent of personal interests. In keeping with this obligation, they are also required to avoid conflicts of interest. In instances where potential or actual conflicts exist, faculty and staff are expected to consult with appropriate University officials implementing this policy to identify potential or actual conflicts of interest and take appropriate steps to manage, reduce or eliminate them.
 
1. SUNY faculty and staff may not engage in other employment which interferes with the performance of their professional obligation (Policies of the Board of Trustees Article XI, Title H, Section 4).
 
2. SUNY faculty and staff are expected to comply with the New York State Public Officers Law provisions on conflict of interest and ethical conduct (Sections 73 and 74).
 
3. SUNY faculty and staff, to the extent required by law or regulation, shall disclose at minimum whether they (and their spouses and dependent children) have employment or financial interests or hold significant offices, in external organizations that may affect, or appear to affect, the discharge of professional obligations to the University (as required and subject to the limits of NYS Public Officer Law 73-a, and 73, 74; 42 CFR Part 50, Subpart F; and, NSF, GPM, Section 310).
 
4. SUNY campuses shall ensure that all faculty and staff subject to pertinent laws and regulations disclose financial interests in accordance with procedures to be established by the Chancellor or designee. Campuses shall retain the reported information as required, identify actual or apparent conflicts of interest and seek resolution of such conflicts.
 
5. Each campus President shall submit to the System Provost the name and title of the person or persons designated as financial disclosure designee(s) and shall further notify the Provost when a change in that assignment occurs. The Provost shall also be notified of any reports regarding Conflict of Interest that are forwarded to State or Federal agencies.


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For more information, please contact the Office of Human Resources, Assistant Vice President Mary Dolan
or e-mail: dolanmk@potsdam.edu.