All employees are to avoid conflicts of interest and conflicts of commitment in the conduct of externally sponsored projects and research projects. This includes even the appearance of a conflict or impropriety. Employees may not engage in activities that interfere with performing job duties and responsibilities at the University. Employees are expected to avoid any situation which compromises job performance, loyalty, or stewardship to the University. This may be considered a conflict of commitment. Employees are expected to avoid participating in decisions or actions on behalf of the University which may result in personal gain to the employee, or the employee’s family or business associates. This may be considered a conflict of interest.
The Uniform Grant Guidance, in 2 CFR 200.112*, requires all Federal funding agencies to establish and publish conflict of interest policies for Federal awards. As an awardee, YSU is also required under these same regulations to disclose, in writing, any potential conflict(s) of interest that exist in connection with the award. Principal Investigators and Project Directors should notify the Office of Research Services immediately upon the receipt of a disclosure or knowledge of an existing or potential conflict of interest.
There are two main conflict of interest provisions in Ohio’s ethics laws that apply to full and part-time employees of the University. First, Ohio Revised Code §102.03 prohibits employees from soliciting or accepting or influencing one to give anything of value when it comes from a party who is interested in a pending matter or doing or seeking to do business with the University. Second, Ohio Revised Code §2921.42 and Ohio Revised Code §2921.43 prohibit public employees from having an interest in a public contract. These statutes also prohibit a public employee’s family and business associates from having an interest in a public contract.
There may exceptions to this prohibition, but each must be approved in advance through the Office of Contract Compliance through the YSU Conflict of Interest Certification Form. In general, these forms are required for employees involved in making purchasing decisions, but may also be required as circumstances change in regards to outside employment, activities that may interfere with YSU obligations, the receipt of gifts of more than a nominal value, and other circumstances outlined in YSU policy.
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