4.15A - Conflict of Interest Procedure

Policy Number - 4.15A

Approved: 03/18/2025

Disclosure of Interests

All employees shall submit a completed Annual Conflict of Interest Disclosure Form. An updated disclosure is required if changes in circumstances arise that (a) create a new conflict of interest or (b) change or eliminate a conflict of interest previously disclosed.

The employee is responsible for updating and resubmitting the disclosure form. The process of disclosure includes the following actions:

Submission of an Annual Conflict of Interest Disclosure Form to Human Resources.
Review of the disclosure by supervisor and the Vice President of Finance and Operations orChief Human Resources Officer. These officials will determine whether a conflict of interest exists and what conditions or restrictions, if any, should be imposed to manage, reduce oreliminate the conflict

Agreements, Contracts and Purchases

College employees shall not knowingly promote and/or enter into any agreement, contract or other binding business relationship on behalf of the College when a conflict of interest exists. Please see Purchasing and Procurement Policy 5.05 for details.

Gifts

College employees who participate in selecting vendors, products and contractors and/or participate in forming business agreements must avoid accepting individual gifts and individual discounts from outside individuals with an approximate value of $25.00 or more. Occasional meals, beverages andother non-extravagant gifts are acceptable if they are not conditioned upon the employee takingofficial action on behalf of the College, and are not repeated from the same vendor. An employee whobelieves he/she may have accepted a gift giving rise to an actual or perceived conflict of interest, should notify his/her supervisor pursuant to this policy.

Employees are encouraged to consider donation of any gifts and/or proceeds for the benefit of thecollege or the KCKCC Foundation. A gift received because of a purchase made by the College will typically be deemed as a gift to the College and not any individual employee, unless the College determines otherwise.

Restraint on Participation

With respect to a particular transaction or item of business, if a supervisor deems an employee to havean actual or significant perceived conflict of interest, that employee shall not participate in the decision for which he/she has the conflict of interest. Decisions related to that transaction or item of business shall be made solely by disinterested employees. In determining whether an employee shall be required to refrain from participation, the supervisor should consider all relevant facts andcircumstances, including whether the contract price is fixed by law or whether the transaction will beentered into solely and exclusively on the basis of the competitive bidding process, in which case, an employee with a potential conflict of interest may still be allowed to participate in some parts of the process.

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