Board of Trustees Policy
Subject: Employee Conflict of Interest
Date: April 2020
Supersedes: December 2010
Montgomery County Community College is committed to the principles of integrity, good faith and fair dealing, and professional accountability in all of its business associations and employment practices.
Accordingly, the purpose of this policy is to provide guidance to all employees on the College’s expectations with respect to any conflict of interest experienced by the totality of any outside interests, concerns and relationships held by any employee, in the course of conducting College business.
In the course of doing College business, actual and potential conflicts of interest are occasionally present. At Montgomery County Community College, a conflict of interest is present whenever one’s professional duties or obligations are compromised, or appear to be compromised, by outside interests or concerns, personal gain or personal relationships.
When presented with a potential or actual conflict of interest, or whenever an employee is in doubt as to whether or not such a conflict exists, the College expects that employee to understand that there is a responsibility to disclose the potential or actual conflict.
In particular, in the event that an employee of the College has an external business or external financial interest in entities that are also doing business with the College, there shall be full disclosure to both the immediate supervisor and to Human Resources, by the employee, as to the exact nature of that business or financial interest.
Additionally, in the event that an employee of the College is in a position to evaluate the candidacy, promotion or tenure of a potential employee of the College with whom that employee has a familial or otherwise close, extra-institutional connection, it is incumbent on that employee to disclose that connection and ask to be recused from the employment decision making process. The same expectation holds for any employee in a position to impact an academic decision with respect to any student with whom that employee has a familial or close, extra-institutional connection.
Supervisors are strongly encouraged to consult with Human Resources in the event of any concerns or questions, with regard to any particular disclosure of a potential or actual conflict of interest, from a subordinate employee.
Following disclosure, employees, when necessary, should recuse themselves from direct involvement in any decision making regarding that business activity or financial enterprise as it concerns the College, unless the College determines otherwise.
Anyone found to be in violation of this Conflict of Interest policy could be subject to progressive disciplinary action, up to and including a recommendation for termination from employment.
Consistent with this policy's duty to disclose any and all potential conflicts of interest, any College employee that has a potential or actual conflict shall complete and submit an annual disclosure questionnaire form (PDF).
Subsequent to a review of, and response to, the disclosed conflict(s) of interest, the processed form shall be kept on file in the office of Human Resources, to be updated by the employee as conditions change, for the duration of the employee’s tenure at the College.