Conflict of Interest

1. Introduction and Purpose

The diverse interactions of Loyalist College employees with students, external organizations and the community is what allows the College to thrive. The public must have confidence that College employees conduct themselves with integrity and in a manner that does not give rise to conflicts of interest. This includes ensuring that the College does not provide preference nor discrimination in favour of or against the employment of a member of an employee’s family for part- or full-time employment.

The purpose of this policy is to set out the College’s standards for the fair and ethical conduct of its employees to avoid any actual or perceived conflicts of interests.

2. Definitions

Conflict of Interest: this occurs when an employee has a private or personal interest that is sufficiently connected to their duties or responsibilities as a College employee that it influences the execution of those duties and responsibilities.

Relative: spouse or common-law spouse, parent, child, sibling.

Ethics Executive: the President and CEO of the College is considered the Ethics Executive for employees of the College. In employment matters pertaining to the President and CEO, the Chair of the Board is the Ethics Executive.

3. Application

This policy applies to all College employees.

4. Policy Statement

An employee shall avoid making or participating in a decision or engaging in any activity that creates an actual or perceived conflict of interest for them. The following activities, though not exhaustive, may constitute instances of conflicts of interests.

• 4.1 Personal Benefit
  • Employees are not to use their affiliation with the College to advance private interests or act in any way that would harm the College’s reputation.
  • An employee should not use or seek to use their affiliation with the College to:
    • Gain personal or financial advantage, directly or indirectly;
    • Solicit or accept favours or economic incentives from individuals, organizations or entities known to be seeking education, employment, contracts or alliances with the College; and
    • Leverage personal or private undertakings that are for unauthorized purposes.
• 4.2 Preferential Treatment
  • An employee shall not:
    • exercise influence for the benefit of related persons;
    • provide preferential treatment to relatives; or
    • receive preferential treatment from individuals or entities based on their employment at the College.
• 4.3 Hiring a Relative
  • Human Resources will ask candidates applying to the College to identify if they have a relative working at the College. This identification shall be made in writing during the recruitment stage. If a conflict is identified, the Executive Director of Human Resources will be notified.
  • Employees at Loyalist College:
    • shall not, on behalf of the College, hire his or her relative;
    • shall not, on behalf of the College, enter into a contract with his or her relative or with a person or entity in which any of them has a substantial interest; and
    • shall ensure that the successful candidate does not directly report to, or directly supervise the work of their relative.
• 4.4 Relatives Working at the College
  • If relatives are working at the College and there is a direct reporting relationship, their relationship must be declared in writing to the Ethics Executive and/or Executive Director of Human Resources. Their relationship:
    • must not create an adverse impact on work productivity or performance;
    • must not create a potential, perceived, or actual conflict of interest; and
    • must not involve direct reporting one another, nor may they audit, review, supervise, direct, discipline, or evaluate each other’s work in any manner.
  • The onus is on the relatives to declare their conflict of interest to their Ethics Executives.
  • Where there is a direct reporting relationship between relatives, the College will make reasonable efforts to adjust the reporting structure to avoid any conflicts of interests.
• 4.5 Privileged Information
  • An employee shall not use privileged information that is gained during the course of their employment with Loyalist to seek to influence a decision made by another person that may further the employee’s private interest or benefit the employee and/or their related persons.

5. Reference Document

• O. Reg. 381/07: Conflict of Interest Rules for Public Servants (Ministry) and Former Public Servants (Ministry)