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Conflict of Interest and Commitment Policy

Responsible Executives: Vice President for Administration, Director of Institutional Research

Responsible Office: Office of the Vice President for Administration

Effective Date[1]: 8/28/2024

Last Reviewed: 8/28/2024

Revised: 8/28/2024

POLICY STATEMENT

HJ International Graduate School for Peace and Public Leadership (“HJI” or the “Institution”) expects all executive officers, faculty, staff, and student employees (together referenced in this Policy as “employee(s)”) to avoid conflicts of interest and conflicts of commitment (as defined below) related to the performance of their obligations to HJI. This statement identifies HJI’s policy in relation to conflicts of interest and commitment and contains its compliance requirements.

This Policy establishes standards of conduct designed to maintain academic, research, and business integrity. It is intended to heighten employee awareness of situations that present either a conflict of interest or a conflict of commitment so that potential conflicts may be avoided, or disclosed and properly managed. This Policy makes every effort to balance the integrity and interests of HJI with those of individual employees. It seeks not only to help employees identify instances where conflicts might arise, but also to assist employees in eliminating or managing actual conflicts and to prevent the appearance of conflicts.

SCOPE

This Policy applies to all employees, whether full-time or part-time. Persons whose employment may be governed by collective bargaining agreements may be subject to related provisions of those agreements, which will supersede inconsistent provisions of this Policy. This Policy is intended to supplement federal and state law requirements as to matters that may include sponsored research, professional ethics, and other conduct standards that may apply to particular professions or disciplines. The Policy is not intended to supersede the institutional policy governing research conflicts of interest, which governs as to all matters within its stated scope.

POLICY

  1. Conflicts of Interest

A conflict of interest exists when (i) an employee, (ii) his/her family member (as defined below), or (iii) an entity in which an employee or his/her family member is an employee, officer, director, member or manager, and/or has any financial or economic interest (excluding, in the case of securities which are publicly traded, ownership of less than 5% of the outstanding securities of any class), has an existing or potential personal, financial or other interest that: (a) might reasonably be expected to impair the employee’s independence of judgment in the discharge of responsibilities to HJI; or (b) may result in personal gain or advancement at the expense of HJI. For purposes of this Policy, a “family member” includes an individual’s spouse or domestic partner; siblings and siblings of an individual’s spouse or domestic partner; ancestors; children, grandchildren and great grandchildren; spouses or domestic partners of siblings, children, grandchildren and great grandchildren; as well as persons with whom an individual has a step-relationship, as applicable, of the type described above and/or others as to whom it would reasonably appear that the individual has a relationship involving an interest in such person comparable to those listed above.

HJI welcomes the employment of family members who wish to work for the Institution, however HJI recognizes that such relationships create unique concerns. HJI will not employ a person in a position where they would be subject to direct supervision by, or would directly supervise, a family member. “Direct supervision” refers to both the direct supervisor-supervisee relationship and any work relationship where one of the employees might be involved in a personnel decision concerning the other.

HJI employees are required to fulfill their responsibilities with due care and loyalty to the best interests of the Institution. The integrity of HJI must be protected at all times, both in actuality and appearance. Conflicts of interest therefore must be: (1) disclosed, and (2) eliminated or properly managed.

Applicable Procedures

Officers of HJI must annually file a conflicts disclosure form on a schedule established and approved the Board of Trustees. Forms must be updated during the reporting period as relevant circumstances change.

Faculty must disclose conflicts of interest as they arise to the Provost using the Conflicts Disclosure Form.

Staff and Student Employees must complete the Conflicts Disclosure Form to disclose conflicts to their supervisors as conflicts arise.

The duty to disclose conflicts of interest as provided in this Policy is a continuing duty, and each individual covered by this Policy shall disclose any conflict of interest involving him or her as soon as possible after he or she learns of it in any context. Disclosure is not limited to an annual or other periodic schedule.

Following an employee’s disclosure of a proposed endeavor or activity that may create a conflict of interest, the matter will be reviewed by his or her supervisor. If the conflict involves a supervisor, the conflict must be disclosed in writing to, and reviewed by, the President. If the conflict involves the President, the conflict must be disclosed in writing to, and reviewed by, the Board of Trustees. 

After discussion with the employee as appropriate, the reviewing official will require one of the following steps to be taken:

  1. no action required beyond the disclosure;
  2. development of a conflicts management plan memorialized in writing;
  3. modification of HJI responsibilities, as mutually agreed, under applicable policies; or
  4. prohibition of the activity in cases of irreconcilable conflicts.

At a minimum, in the event that the reviewing official determines that a conflict of interest exists, he or she shall require that the employee not be present at or participate in any deliberations, discussions, and/or decisions relating to the matter with respect to which the conflict exists, or attempt to improperly influence any deliberations or voting regarding the matter.

Prohibited Conflicts of Interest

The following conflicts of interest are expressly prohibited, and must be managed as set forth below:

  • Making a decision to employ, promote, or terminate a family member; or setting salary or wages, approving time cards or employment records for, or evaluating the performance of, a family member. Where, by virtue of reporting lines, an employee would otherwise make these decisions regarding a family member, an appropriate alternative administrator must be designated by the President. If the employee is the President, the designation must be made in consultation with the Board of Trustees.
  • Negotiating or authorizing on behalf of HJI a contract or other business transaction for services, goods, or products, from a company or enterprise in which the employee or his/her family member is an employee, officer, director, member or manager, and/or has a financial or economic interest as described above. Where, by virtue of position, an employee would otherwise make these decisions, an appropriate alternative administrator must be designated by the employee’s supervisor in consultation with the Vice President for Administration. If the employee is the Vice President, the designation must be made by the President. If the employee is the President, the designation must be made by the Board of Trustees.
  • Approving forgiveness of a debt of HJI to an external entity in which the employee or his/her family member is an employee, officer, director, member or manager, and/or has a financial or economic interest as described above, or forgiveness of a debt of such an entity to HJI. Where, by virtue of position, an employee would otherwise make these decisions, an appropriate alternative administrator must be designated by the employee’s supervisor in consultation with the Vice President. If the employee is the Vice President, the designation must be made by the President. If the employee is the President, the designation must be made by the Board of Trustees.

Other Prohibited Conduct

The following conduct, even if not involving a conflict of interest as defined above, is prohibited:

  • Accepting, soliciting, or offering bribes, kickbacks, payoffs, or other improper incentives or payments from or to a third party or another employee in the course of HJI employment.
  • Accepting cash or non-cash gifts of any type having more than nominal value, including goods, services, travel, or entertainment, at no cost or discounted prices, from persons or entities doing business with HJI, in consideration of the employee’s HJI business or professional relationship with the person or entity.  (This prohibition does not, however, include honoraria, meals, or reimbursement of reasonably incurred travel expenses in consideration of a speaking or comparable appearance made or given by an employee in his/her professional or official capacity, whether in relation to external or HJI activities).
  • Disclosing, or otherwise using on an unauthorized basis, HJI confidential or proprietary information to which the employee has access in the course of HJI duties.
  • Employing HJI employees or students, over whom the employee has supervisory responsibility or authority, for non-HJI endeavors or activities without approval of the Vice President. If the supervisory employee is the Vice President, approval must be obtained from the President. If the supervisory employee is the President, approval must be obtained from the Board of Trustees.
  • Accepting any form of remuneration, financial or otherwise, for endorsement of the products or services of a business or individual where an HJI title or employment is an express or implied aspect of the endorsement, without approval of the applicable supervisor. If the employee is a supervisor, approval must be obtained from the President. If the employee is the President, approval must be obtained from the Board of Trustees.
  • Acquiring or holding any financial interest in an entity that competes with the Institution, excluding interests held in publicly traded companies.
  • Serving as an executive officer or on the board of directors of a for-profit or non-profit entity, such as a corporation, association, or partnership, regardless of remuneration, that interacts with HJI in ways that might result in undue benefit to the other organization.
  1. Conflicts of Commitment

The paramount work commitment of a full-time HJI employee is to his or her position at HJI. It is the responsibility of the employee to manage his/her external activities so that they do not interfere with his or her HJI obligations. A conflict of commitment occurs when external activities undertaken by an HJI employee will or reasonably can be expected to interfere with his or her ability to perform their HJI responsibilities fully or effectively.

Employees who wish to engage in activities, including external employment, compensated independent consulting, and uncompensated activities, that will or reasonably can be expected to interfere with their HJI responsibilities must inform their supervisors in writing of the proposed activity before making the commitment.

Promptly after receipt of the written disclosure, the supervisor will schedule a meeting with the employee to discuss how to manage the situation.

The supervisor and the employee must attempt to develop a written conflict management plan. The plan may include monitoring the activity to ensure that employees are able to complete their HJI obligations, modification of assignments (including any commensurate compensation reduction), or a leave of absence arranged under otherwise applicable leave policies. If agreement cannot be reached on a plan, the supervisor will inform the employee that he or she must fulfill HJI responsibilities and inform him/her of the possible consequences of failing to fulfill these responsibilities.

Other Outside Activities

All employees have a primary commitment to HJI and will be sensitive to the possible adverse effects of their external activities. HJI encourages participation in community and civic activities. Employees who consider serving in elected or appointed positions on local government councils, boards, commissions, or similar entities are required to disclose such part-time opportunities with their supervisors to ensure that there is no conflict with their primary commitment to HJI. Employees must recognize that the appearance that a conflict may be present is as important as the reality. 

Many outside activities in which an employee may wish to engage, such as certain outside employment, private activities, involvement in public organizations, public service, and political involvement, present no conflicts of interest and can enhance the reputation of HJI. When engaging in an otherwise permissible endeavor or activity, the employee must nonetheless make clear when she or he is acting as a private individual rather than as a representative of HJI. In this regard, employees must abide by the terms of HJI policies governing use of trademarks and use of HJI’s name, symbols, letterhead, and other proprietary indicia of affiliation.

  • Reporting of Possible Policy Violations

Supervisors are required to investigate promptly possible violations of this Policy. If a policy violation is proven, the supervisor must take appropriate responsive action, which may include disciplinary measures up to and including dismissal. Possible violations may be reported to the employee’s supervisor or the Vice President for Administration. No retaliatory action will be tolerated on the part of an HJI employee or official against persons making such a report in good faith and/or cooperating with an investigation of such a report.

RELATED INFORMATION

  • Conflicts Disclosure Form

[1] All preexisting policies with the exception of the Board of Trustees Conflict of Interest Policy covering the same subject matter as these policies are superseded as of the effective date of adoption of this Policy.