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Conflict of Interest Prevention

What is a Conflict of Interest?

Conflict of interest occurs when professional duties and personal interests intersect, putting a person in a position to personally benefit from a decision made as part of his or her job duties. As public employees, California State University (CSU) employees are subject to various conflict-of-interest-related laws and regulations.

The primary California legislative document governing conflicts of interest is the Political Reform Act of 1974 (the Act), which prohibits public employees from making, participating in making, or in any way attempting to use their official position to influence a governmental decision in which they know, or have reason to know, they have a financial interest. This applies to all CSU employees. Primary responsibility is placed upon the individual employee to be familiar with the requirements of the Act. In addition, if CSU employees have a personal financial interest in a university decision, they are required to publicly announce the financial interest and disqualify themselves from involvement in the decision. CSU employees should also be sensitive to the appearance of conflict of interest when participating in university decisions, even when a true conflict does not exist.

Conflict of Interest Code

The California Political Reform Act requires certain state and local government officials to publicly disclose their private economic interests on the Form 700, Statement of Economic Interests. Additionally, it requires that all government (University) employees disqualify themselves from participating in decisions in which they have a personal financial interest.

Designated Positions

In alignment with state law, the CSU’s Conflict of Interest code requires Employees in Designated Positions (PDF) to:

  1. Annually complete a statement of economic interests (Form 700 or Form 700-U), and
  2. Take related training.  The California Fair Political Practices Commission (FPPC) regulates this process.  Requirements are codified in California Code of Regulations (CCR), Title 2, Division 6, §18734 [disclosure requirements] and Education Code (EC) §89500.7 [training].

Training

California State law mandates that employees who must file a Statement of Economic Interest Form (FPPC Form 700), or designated employees, must take an ethics training every two years or within six months of first assuming their designated position. Employees in Designated Positions are likely to encounter decisions where a conflict of interest might arise.  The CSU further designates its employees must take a CSU-specific Conflicts of Interest training.

Statement of Economic Interests (Form 700 and Form 700-U)

Employees in Designated Positions are also required by state law to file a Statement of Economic Interests (Form 700) on an annual basis. [Principal Investigators complete a CSU Form 700-U.] Each designated position has been assigned disclosure categories based on the position description. For more information, please refer to the "Resources" below or contact the campus COI filing officer at coi@csuchico.edu, (530) 898-6771.

  • The Form 700 process alerts employees to potential conflicts of interests
  • Employees must report potential conflicts of interest
    • Disclosure on Form 700 is not enough
    • Employees must report to supervisor
    • Campus/COI Officer must analyze whether employee has a conflict and if so, should be removed or disqualified from related decisions

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Gifts to Agency

Frequently Asked Questions (FAQ)

Which positions are on the campus Designated Positions list?

The campus Designated Positions list includes many employees in MPP positions, all Procurement Card Holders, and some Independent Contractors, and Principal Investigators of grants and contracts. It includes anyone who has authority over a budget or can make purchase decisions. The CSU has defined criteria for defining a Designated Position as follows.

Makes, participates in, or influences decisions regarding:

  1. The physical master plan of the university.
  2. The total enrollment of the university.
  3. The license, lease, purchase, or sale of real property of the university or for the university.
  4. Purchase of supplies, materials, commodities, machinery, equipment, services, or work for the university, school, department, or area.
  5. Entering into/amending construction contracts or service contracts in connection with construction contracts for the university.
  6. Investment of university funds.

How do faculty get on the campus Designated Positions list?

Individuals were identified by Faculty Affairs as having Assigned Weighted Teaching Units (AWTU) responsibilities that appear to meet Conflict of Interest requirements.  As a result, their names and position--Faculty with Directorship Duties (AWTU)--will be added to the campus Designated Position list and they will need to complete a Form 700 and CSU Conflict of Interest (COI) training.

If they have already completed a Form 700-U for the Research Foundation, this is an additional requirement for their State position.  If they have completed COI training in the last 2 years, they will not need to complete it again until just prior to their due date.

What are key takeaways from the COI training?

  • disqualify yourself from decisions in which you have a financial interest
  • properly report gifts and financial interests on your FPPC Form 700
  • file Form 700 every year by April 1st or within 30 days of assuming a new designated position
  • avoid even the appearance of impropriety
  • seek advice if you have any questions

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Resources


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Need Help?

If you have questions or feel a specific position does not meet the criteria above, please contact the campus COI filing officer at coi@csuchico.edu, (530) 898-6771.