Specifically, and effective July 1, 2023, employee disclosure and prior approval is required where noted in the following situations.  Examples of the following situations can be referenced on the portal at Business Policy and Procedures - Southeast Missouri State (semo.edu).

•     Financial Conflicts: An employee purchases or influences the acquisition of equipment, goods, devices, or services for University use or with University funds from an individual, firm or organization: 1) in which the employee or his/her immediate family members have a current or contemplated financial interest or 2) if the employee is also employed by, or is negotiating or has an arrangement concerning prospective employment with, that individual, firm, or organization.  Requires advance disclosure by the employee and approval by division executive and the Vice President for Finance and Administration. 
•      Externally Funded Research: An employee has a potential conflict of interest with respect to externally funded research projects, as governed by University Business Policy 11-02: Sponsored Projects Financial Conflict of Interest.  Requires disclosure by the employee to the division executive and Office of Research and Sponsored Programs.    
•     Employment of Immediate Family Members:  Employees and their immediate family members may not be assigned to positions in which one family member has direct administrative or supervisory responsibility for the other or would be in a position to influence the terms and conditions of the other person’s employment.  
•      Faculty and Staff Outside Employment: An employee accepts outside compensated employment which overlaps with the University’s teaching, research, or service missions.  Requires advance disclosure by the employee and approval by the division executive.
•      Consultation by Employees: An employee consults with an entity that transacts business with the University, is in competition with the University, where the consultation itself competes with the work of the University.  Requires advance disclosure by the employee and approval by the division executive.         
•      Gifts, Favors, or Gratuities:  An employee may not accept personal gifts or favors exceeding $200.00 in any calendar year from any single person, company, or firm which transacts, or wishes to transact business with the University.  
•      Use of University Stationery or Logos: An employee uses the University name or any of its graphic identification symbols in printed materials intended to endorse or promote individual enterprises or to otherwise enhance private gain.  Requires advance disclosure and prior approval by the University President.  
•      Unauthorized Use of or Access to Information, Programs, Resources or Technology:  Employees may not use University programs, resources, services, or technology to advance their outside consulting or business activities, for personal gain, or for any other unauthorized purposes. Unless required by law, or business necessity, employees may not disclose, provide, or transmit to a private individual, firm, or entity access to any University-owned work product, proprietary research results, materials, services, facilities, technology, records, confidential or privileged information, or other resources that are not made generally available to the public.
•      Faculty Grading Conflicts: Faculty members are discouraged from teaching an immediate family member and should not do so unless such assignments are unavoidable due to programmatic need.  Moreover, faculty members should not grade, including conferring or cooperating to assign a grade to, immediate family members.  Prior disclosure is required to the chairperson and dean.  
•      Assignment of Materials: A faculty member assigns his/her own texts or publications for classroom use where such assignment requires students to purchase a text or publication in which the faculty member has financial interest in the sale or licensing of such materials.  Prior disclosure and approval are required by the Provost.   

To provide disclosure and obtain prior approvals as required per policy guidelines, employees should complete the online disclosure form in myworkflows.semo.edu, under the Human Resources tab.  All disclosures and associated approvals will be retained in employee personnel records.  

Full compliance with the updated policy and operating procedures, including the submission of any disclosures and requests for prior online consent and approval, is expected beginning July 1, 2023.       

On-going compliance throughout the year is also expected if necessitated by changed circumstances and events. As stated in the policy, an employee’s failure to disclose conflicts or potential conflicts on a timely basis will be addressed by the University and may form the basis for discipline, up to and including termination of employment.

Questions regarding University Business Policy and Procedures 01-07: Conflict of Interest and its associated disclosure/prior approval requirements should be directed to Human Resources at (573) 651-2206