Conflicts of Interest Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Spelman wishes the College to operate. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of Spelman's business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. No "presumption of guilt" is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to the Office of Human Resources or the Vice President of Business and Financial Affairs, 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 or relative has a significant ownership in a firm with which Spelman does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Spelman. Employees must disclose any financial interest they or their immediate family have in any firm that does business with Spelman College. The College may require divestiture of such interest if it deems the financial interest to be in conflict with its best interests. Please be aware that all actual conflicts must be reported to auditors and other regulatory agencies. The College may require employees to complete a new conflict of interest statement annually. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact your supervisor or the Office of Human Resources for more information or questions about conflicts of interest. Final decisions regarding potential Conflicts of Interest will be made by the Vice President of Business and Financial Affairs. Policy No.  108  Effective Date:  9/1/2000  Revision Date:  6/1/2002