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George Wythe Foundation

Conflict of Interest Policy

It is in the best interest of George Wythe University (“GWU”) and its mission1 to be aware of, avoid, properly mitigate, and manage all potential conflicts of interest and appearances thereof. This Policy is designed to help trustees, officers, employees and volunteers of GWU and George Wythe Foundation (“GWF”) (collectively and separately referred to as “the University”) identify situations that present potential and perceived conflicts of interest and to provide a procedure to appropriately manage conflicts in accordance with legal requirements and the goals of accountability, ethics and transparency in the University’s operations.

Policies

No trustee, committee member, officer, employee, or volunteer (or family members2 of any of the foregoing) of the University (collectively and separately referred to as “Associate”) shall derive any personal profit, gain or advantage, directly or indirectly, by reason of his or her relationship with the University.

An Associate shall disclose to the University any interest that he or she has or may have in any matter pending before the University and its boards, committees, officers and employees and shall refrain from participation in any decision on such matter.

No Associate may pursue any business activity3 that is in direct competition with the University.

No Associate may have any business activity advertised or otherwise supported by the University.

No Associate may receive any remuneration from the University based on a per capita or percentage basis.

No Associate may participate in any profit sharing activities with the University.

No Associate will receive royalties on the sales to students and instructors of any books or other materials required at GWU.

GWU shall not enter into an affiliation or other business relationship with any for-profit business with significant ownership held by a current or former Associate. Such an organization may only be considered for the provision of services to GWU after a formal open bid process against competitors, and, if chosen, the relationship may be maintained only under a strict, arms-length contractual arrangement. Such proposals may still be rejected at the sole discretion of the board of trustees.

All intellectual property created by an Associate while in the capacity of or in the context of the Associate’s relationship with the University will be the exclusive property of the University, unless previously agreed in writing.

Other situations may create the appearance of a conflict of interest, or present a duality of interests in connection with a person who has influence over the activities or finances of the University. All such circumstances should be disclosed to the board, officer or staff, as appropriate, and a decision made as to what course of action the University or individuals should take so that the best interests of the University are not compromised by the personal interests of the Associate.

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 or favor does so under circumstances where it might be inferred that such action was intended to influence or possibly would influence the person in the performance of his or her duties or decisions. This does not preclude the acceptance of gifts, entertainment or favors of nominal or insignificant value which are not related to any particular transaction or activity of the University.

Procedures and Training

Trustees and administrators should guard vigilantly against all potential conflicts and appearances of conflicts that may arise. These should be declared and discussed in order to seek avoidance and resolution as soon as they are noticed. Additional procedures may be implemented by administration as deemed appropriate by the Board of Trustees.

The ultimate determination of a conflict of interest, its potential or the appearance thereof shall be made at the judgment and discretion of the Board of Trustees. A person identified as having a potential conflict of interest shall not participate in or be permitted to hear the board's discussion of the matter except to disclose material facts and to respond to questions. Outside of the board's formal deliberations, such person shall not privately attempt to exert his or her personal influence among board members with respect to the matter. The Board will disclose its final decision to the person in question as well as its reasoning for the decision.

In addition to trustees and administrators, all employees and volunteers must also be trained appropriately with regard to this Policy as part of their earliest official orientation.

 


1Mission is both the institution’s stated mission of building statesmen as well as its obligation as a 501c3 organization to serve the public interest.

2Family member is defined as a spouse, parent, child, brother, or sister, and spouse of any of them.

3Business activity is defined as any activity that provides financial remuneration, whether monetary or in kind, but does not include regularly salary.

Approved by the GWF Board of Trustees, July 2010.

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