19.7 Conflict of Interest

All employees have an obligation to conduct themselves within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which FNU wishes the Institution to operate.

The purpose of these guidelines is to provide general direction regarding acceptable standards of operation. Employees are encouraged to seek further clarification on issues relating to acceptable standards.

Transactions with outside companies must be conducted within a framework established and controlled by the executive-level of FNU. Executive-level refers to Owners, President, or other officers of FNU. Business dealings with outside companies should not result in unusual gains for those companies, or any unusual gains for the FNU employee conducting such business.

Unusual gains refer to bribes, product bonuses, special fringe benefits, unusual price breaks, gifts and other windfalls designed to ultimately benefit either the employee, the outside University, or both.

Any promotional plans that involve selling FNU products/services or purchasing products/services from outside companies that could be interpreted as having an unusual gain will require specific executive-level approval.

An actual or potential conflict of interest occurs when an employee is able to influence a decision that may result in a personal gain for such employee or a personal gain for a friend, relative, or any other acquaintance of such employee, as a result of the University’s business dealings.

If an employee has any influence on transactions involving purchases, contracts, or leases, it is imperative that he/she disclose it to an officer of FNU, as soon as possible, the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.

Personal gain may result not only in cases where an employee, relative, friend or any other acquaintance has a significant ownership in a university with which FNU does business, but also when an employee or any related party receives any kickback, bribe, gift, or special consideration because of any transaction or business dealings involving FNU.