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POLICY STATEMENT

Prince Sultan University requires all PSU members including members of the academic and administrative bodies, Board of Trustees, committee members at all levels, advisory boards, the governing body and students.to avoid any conflict between their interests and those of the university and to disclose promptly any actual or potential conflicts. Conflict of interest also includes persons directly related to the PSU members, such as husband, wife, son, daughter, brother or sister.

BACKGROUND AND JUSTIFICATION:

For an academic institution like Prince Sultan University to be successful, conflicts of interest must be resolved. It has an immediate effect on the reputation, public trust, and general efficacy in accomplishing vision and mission of the University. Through proactive detection and handling of conflicts of interest, the University can safeguard its reputation, uphold the trust of its stakeholders, and guarantee that the quality of the education and the running of the university as a whole are highly estimable.

SCOPE AND PURPOSE

All PSU members are expected to conduct work and duties with high levels of ethical standards and integrity. It is important that they are aware of situations that may negatively impact their integrity and ethical standing. This policy defines what could be a conflict of interest and states how conflict of interest situations can be handled.

This policy addresses the circumstances in which conflicts of interest or commitment may occur, provides examples of the principles and processes outlined in this policy, and specifies a process for resolving potential conflicts. This policy is essential for maintaining trust, transparency, and ethical standards within the university community.

The purpose of this policy is to:

• ensure that the name, reputation, and integrity of the university are not compromised.
• protect university members from questionable circumstances and transactions that may negatively affect their careers and protect PSU reputation and interests.

This policy is read together with the other University’s policies:

Compliance Investigation Policy: https://psu.edu.sa/en/cop004-compliance-investigation-policy

Compliance Reporting Policy: https://psu.edu.sa/en/cop003-compliance-reporting-policy

Disciplinary Policy: https://psu.edu.sa/en/cop005-disciplinary-policy

PRINCIPLES OF THE POLICY

The fundamental principles guiding the implementation of the policy are the following:

• No personal interest: no employee should have, or appear to have, any personal interests, relationships, or affiliations that conflict with the best interests of the university.
• Accountability: All interested parties are accountable for disclosing and/or identifying their own conflict of interest and complying with the directions or orders of the higher management to handle such conflicts.
• Transparency: This policy requires all stakeholders to disclose any potential conflicts of interest in order to ensure the relevant information is available for review by the appropriate entities.
• Integrity: Upholds the integrity of decision-making process by ensuring that decisions are made based on the best interest of the organization or the PSU community, which is free from undue influence of interest.
• Fairness: The policy is applicable equally to all stakeholders, ensuring everyone is subject to the same rules and procedures mentioned in the policy.
• Protection: This policy protects the interests of all stakeholders to prevent harm that may arise due to conflicts of interest.
• Proactive: Facilitates proactive identification and management of potential conflicts before they result in bias, inappropriate actions, or unacceptable results.
• Compliance: Ensure that PSU complies with the relevant laws, regulations, and professional standards regarding conflict of interest in all academic, administrative, and governance areas.
• Responsiveness: This policy and it enforcement mechanism are responsive to new situations that may arise, which results in re-evaluating the management plans.

DEFINITIONS

Conflict of interest: is a situation where the university member’s personal interests (financial, professional or other personal considerations) may affect directly or indirectly his/her judgment in conducting any university duty, executing transactions, representing the university, or has some influence on his/her roles and responsibilities.

University Member: is used to cover all types of university stakeholders, including senior administration, faculty members, visiting faculty, staff and other types of employees, Board of Trustees and Advisory Boards.

RESPONSIBILITIES AND IMPLEMENTATION STRATEGIES

• University members should use good judgment, professional commitment and ethics to protect themselves and the university from potential conflicts.
• University members holding higher management position must to disclose the nature of the conflict (e.g. receiving benefits) to others involved in the university business decision making. In such situations, the PSU members may not be involved in decision making.
• University members must disclose any of their financial interests in organizations or companies dealing with the university. This includes property interests, labor relations and advisory arrangements.
• The Heads of the Departments including both administrative and academic and employees should make employees aware of this policy and create, by example, an environment consistent with the university's missions.
• University members should disclose to the appropriate dean or head of the department potential conflicts of commitment or interest, before planning outside employment or consulting activities.
• Disclosure on issue related to the conflict of interest must be made in writing to the university Compliance Office or any other relevant office.
• The Compliance and Legal Office or any other relevant office is responsible to take suitable actions if any of the stakeholders, faculties or students’ report on non-compliance with this policy.

PROCEDURES FOR HANDLING POLICY VIOLATION

Modes of initiation of complaints on violations: (Any one of the following modes will be accepted)

1. Report to the line managers
   Line managers are responsible for ensuring the implementation of this policy:
   to record the complaint received from University member
   to investigate the complaint and verify the accuracy of the report and evidence
   to submit the complaint to the disciplinary board through the Compliance Office
2. Report to the Compliance Office
   The report can be verbal or written.
3. Report through Google Form
   The form is available online at:
   https://forms.gle/AmnUEUgawRH6J4ud8

Procedures of the Compliance and Legal Office

Upon receiving the report of violation from any mode either (1) or (2) or (3) above the Senior Compliance and Legal Manager shall analyze the report and identify the type of cases either it is no basis (no prima facie) or disciplinary or a grievance.

On the other hand, if the report received from the complainant is not complete, the Senior Compliance and Legal manager may request further evidence from the complainant (if necessary) upon which the complainant shall respond within 7 days. Otherwise, the report shall be considered as not valid and consequently it will be closed.

In a situation where the Senior Compliance and Legal Manager is satisfied there is a case (prima facie), it shall be presented either before the Grievance Board or Disciplinary Board, as the case maybe.

The respective Board shall conduct the hearing and gives initial recommendations. Such recommendations shall be forwarded to the Senior Compliance and Legal Manager for final decision.

Within 7 days after the final decision is issued by the Senior Compliance and Legal Manager, the affected party/ies may file an appeal. Such an appeal shall be presented before the Higher Disciplinary & Grievance Board (HDGB). The Senior Compliance & Legal Manager will update the decision/verdict of the HDGB who shall then release the said decision/verdict to the Office of President.

If no appeal is filed, the Senior Compliance & Legal Manager shall release the decision/verdict directly to the Office of President.

APPENDICES:

Examples of Conflict of Interest include, but not limited to:

• Personal Benefits: Conflict of interest can be reported, when a university member uses his or her position to influence university decisions to gain personal benefits from a deal or transaction related to PSU.
• Using PSU resources: Resources such as facilities, equipment or personnel for personal projects or any outside activity without proper authorization.
• Misusing confidential information: Information obtained through various positions at PSU for personal or third-party benefits.
• Procurement: Purchasing of goods ordered by the university from companies and organizations in which the member has some direct or indirect interest (shareholder or ownership).
• Compromised Commitments: Conflicts of interest arise when university members' involvements in outside activities substantially interfere with their commitments to the university: to teach, to conduct research and to meet related obligations to students, colleagues and the university.
• Accepting Gifts: Accepting gifts, hospitality and other benefits from individuals or organizations that influence the recipient’s decision for the university or the PSU member.
• Recruitment: University member may not appoint or promote a relative to a post at the university if the staff member has the authority to make such a decision. This decision applies to all relatives, including spouses, fathers, sons, siblings, in-laws and up to the fourth degree.
  Exceptions to the above are:.
  University member may appoint a relative if the relative is the most qualified candidate for the post.
  University member may appoint a relative if he or she is appointed to a position that does not cover the employee's area of responsibility, so that the employee does not directly head him or her and is not responsible for his or her direct evaluation or promotion.
  If the University member is considering hiring or promoting a relative, they must first consult the university's compliance officer, who will review the situation and determine whether recruitment or promotion is permitted considering the conflict of interest policy.
• Recognitions and/or Competitions: It may be a conflict of interest if selection of students or faculty for any PSU recognition/event is based on personal acquaintance with him/her.
• Financial Interest: It may fall under the following situations:
  Ownership or some direct or indirect interest by the member in property leased or purchased by PSU.
  Holding of direct or indirect investment by the member in an entity or organization providing services to PSU.
  Receipt of cash, services or resources from an external organization providing services to PSU.
• PSU Information: Use of information received as a university member for personal purposes.
• Consultation Services: University members are regularly involved in consulting activities from which they profit financially. As a rule, such activities are not a conflict as long as:
  University resources (computer or research laboratories, studios, equipment, computational facilities and/or human resources) are not used without a prior approval of the university, either using free or reimbursing the university.
  Such consultation activities do not disproportionately interfere with the time committed by the PSU members to their primary responsibilities to the university. University members should adhere to the time as stipulated in the consulting policy as approved by the authority in the University.
• Competition with the PSU: University members should not get involved in direct competition with PSU either personally or through any external entity in which the PSU members have a substantial interest.
• Intellectual property and academic activities:
  In academic research, the term conflict of interest may also refer to:
  Situations in which financial or other personal interests may negatively impact the investigator’s professional judgment in conducting or reporting research. The bias can affect collection, analysis, and interpretation of data, the use of appropriate statistical methods, or even faking the outcomes.
  Manipulating institutional or research data for personal gains or third-party with some vested interest.
• Accreditation: In accreditation, the conflict of interest arises if the institutional or college or program leaders are aware of any past associations, or conflicts of interest that could undermine the independence of the external review.
• External Examiners: The external examiners appointed for evaluating students’ course work or senior projects have an association (relative, family, friends etc.) with students or the supervisor.
• COOP Trainings: The students taking any COOP training at an organization owned or supervised by close relatives.
• Outside Commitments: The university actively encourages involvement in Boards of Trustees, professional organizations, panels, advisory boards, charitable, and community organizations. However, such involvement should not become so dominant that university members no longer effectively satisfy their responsibilities to the university e.g., if it demands a significant portion of the individual’s time and attention, leading to distraction from the PSU’s responsibilities.

Approved:

PSU University President