For purposes of this policy, a person with a conflict of interest is referred to as an “interested person.” The following circumstances shall be deemed to create a Conflict of Interest:
- • Ownership of some or all of an institution, its assets or the stock of the company that owns or operates the institution;
- • The holding of mortgages, liens, or other debt instruments or interest upon an institution or its assets;
- • Having been employed, or currently employed, at the institution;
- • Currently employed with a DEAC institution that competes with the institution;
- • Having served, or currently serving, as a consultant to the institution;
- • Having served, or currently serving, on a Board, Advisory Council, or Committee of the institution;
- • Having attended the institution as a student;
- • Having financial interest (including holding stocks, etc.) in the institution or a business or enterprise that competes with DEAC;
- • Having a close personal friend or family member at the institution; or
- • Having accepted gifts, entertainment or other favors from individuals or entities (see below).
Other situations may create the appearance of a conflict
, or present a duality of interests
in connection with a person who has influence over the activities or finances of the DEAC.
All such circumstances should be disclosed to the DEAC Executive Director, as appropriate, and a decision made as to what course of action the organization or individuals should take so that the best interests of the DEAC are not compromised by the personal interests of stakeholders in the DEAC.
Gifts, Gratuities and Entertainment
: Accepting gifts, entertainment or other favors from individuals or entities can also result in a conflict or duality of interest when the party providing the gift/entertainment/favor does so under circumstances where it might be inferred that such action was intended to influence or possibly would influence the interested person in the performance of his or her duties. Souvenirs (typically available to the public) are permissible, but should be restricted to inexpensive items representing the institution.