Policy Statement

Prince Sultan University requires all employees to avoid any conflict between their interests and those of the University, and to disclose promptly any actual or potential conflicts.

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 all employees and faculty members be 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.

The purpose of this policy is to ensure that the name, reputation, and integrity of the University are not compromised. To protect university members from questionable circumstances and transactions that may negatively affect their careers and protect PSU reputation and interests.

The fundamental principle guiding its implementation is that no employee should have, or appear to have, any personal interests, relationships, or affiliations that conflict with the best interests of the University.

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 employees, including senior administration, faculty members, visiting faculty, staff and other types of employees.

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

1. Conflict of interest can be reported, when a member uses his position to influence university decisions to gain personal benefits from a deal or transaction related to PSU.
2. Purchasing of goods ordered by the university from companies and organizations in which the member has some direct or indirect interest (shareholder or ownership).
3. Conflicts of interest arise when university members' involvements in outside activities substantially interfere with their primary commitments to the university: to teach, to conduct research and to meet related obligations to students, colleagues and the university.
4. Receiving gifts or special favors from potential vendors or providers of services to PSU.
5. Receiving gifts from the students taking a course or courses with a course instructor.
6. Teaching a student with whom there is a close acquaintance.
7. Selecting students or faculty for any PSU recognition/event based on personal acquaintance with him/her.
8. Ownership or some direct or indirect interest by the member in property leased or purchased by PSU.
9. Holding of direct or indirect investment by the member in an entity or organization providing services to PSU.
10. Receipt of cash, services or resources from an external organization providing services to PSU.
11. Use of information received as a university member for personal purposes.
12. 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. The allowable amount of time dedicated to consulting will be governed by the Consulting Policy. University members should adhere to the time as stipulated in the consulting policy.
13. 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.
14. 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.
15. 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.
16. The university actively encourages involvement in board 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.

Responsibilities:

1. University members should use good judgment, professional commitment and ethics to protect themselves and the university from potential conflicts.
2. 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.
3. Administrators and supervisors should make employees aware of this policy and create, by example, an atmosphere consistent with the university's missions.
4. University members should disclose to the appropriate dean or department head potential conflicts of commitment or interest, before planning outside employment or consulting activities

Procedure for reporting and handling a Conflict of Interest

1. Reporting a Conflict of Interest
   1. The perception of conflict of interest may vary from one individual to another, the appropriate approach to clarify the case is to establish a disclosure system through which a member discloses potential conflict of interest and receives an evaluation from the university.
   2. All university members are required to disclose any potential conflict of interest through a disclosure system.
   3. The university will respond to such requests with clear answers, either clearing the member, or otherwise handle the case in a manner that protects the member and university interests.
2. Handling a Conflict of Interest Situation

   On receiving a conflict of interest disclosure, the respective PSU entity Compliance Office appoints a committee to gathers information from the Disclosure System, and investigate if there is a real conflict of interest, and what is the level of the risk? Based on the investigation, there are three possible outcomes:

   1. No Conflict of Interest exists in this case, no further investigation is required, and the member is cleared to proceed.
   2. A Conflict of Interest exists, but the risk is manageable: the respective office, in cooperation with the member prepares a memorandum of understanding detailing how the conflict of interest will be managed. The memorandum should be signed by the PSU member.
   3. A significant Conflict of Interest exists and the risk to the University cannot be managed: A memorandum of understanding is prepared in cooperation with the member detailing how the conflict of interest will be eliminated. The memorandum should be signed by the member.

References

Conflict of Interest Policy was formulated based on Carnegie Mellon University Policy.