RSCC Policy GA-35-01; Conflict of Interest

Roane State Community College

Policy Number: GA-35-01

Subject: Conflict of Interest

All Roane State Community College employees serve the interests of the State of Tennessee and its citizens and have a duty to avoid activities and situations that, either actually or potentially, put personal interests before the professional obligations that they owe to the state and its citizens. This policy is intended to define the general principles which should guide the actions of an employee of the Tennessee Board of Regents (TBR) which includes employees within Roane State Community College (RSCC). The policy offers illustrations of activities which potentially constitute a conflict of interest, makes RSCC employees aware of disclosure requirements related to conflicts of interest, describes the process by which those disclosures shall be evaluated and decisions rendered, and describes the appeals process regarding such decisions.
Definitions
1. Conflict of interest – occurs when personal interests (financial or otherwise) diverge from professional obligations to RSCC/TBR.
2. Conflict of commitment – occurs when non-work activities impair an employee’s ability to fulfill job responsibilities.
3. Conflicting party – Any person or entity seeking business or financial relations with RSCC that may be affected by the employee’s actions.
4. Immediate family – for purposes of this policy means spouse, or minor child living with the employee.
General Principles
1. Employees of RSCC should avoid external commitments that significantly interfere with the employee’s duties to the institution, Disclosures of outside employment shall be made as required under TBR policy 5.01.05.00 Outside Employment and Extra Compensation for Additional Assignments and evaluated as indicated in that policy.
2. Employees of RSCC should avoid situations where the self-interests of the employee diverge from the best interests of the institution.
3. Conflicts may be managed, reduced, or eliminated; not all require elimination.
4. When the potential detriment to the institution is at most minor and inconsequential, and the conflict does not indicate violation of Federal or State law, regulation, or policy, those persons charged with evaluating disclosures should allow the activity to proceed without interference after documenting the evaluation process.
5. For those situations which do not implicate Federal or State law, regulation or policy, the standard for determination of whether a conflict of interest should be managed, reduced, or eliminated is whether that conflict would appear to a reasonable person to call into question the integrity or judgment of the affected employee.
Situations and Activities Creating a Conflict of Interest
1. In the following situations and activities, there is at least the appearance, and possibly the actuality, of an employee allowing his or her personal interests, and not the best interests of the TBR and its constituent Institutions, to affect that employee’s judgments. This list is illustrative, and not exhaustive.
  1. Self-dealing is considered as influencing decisions for personal or family financial gain.
  2. Use of educational materials from which a faculty member derives financial benefit in that faculty member’s teaching activities.
  3. Acceptance of Gifts, Gratuities, or Favors – No employee shall knowingly solicit or accept, directly, or indirectly, on behalf of himself or herself or any member of the employee’s household, for personal use or consumption any gift including but not limited to any gratuity, service, favor, food, entertainment, lodging, transportation, loan, loan guarantee or any other thing of monetary value, from any person or entity.
2. Exceptions
  1. The prohibition on accepting gifts in Section (IV)(1) above, does not apply to:
    1. A gift given by a member of the employee’s immediate family, or by an individual, if the gift is given for a non-business purpose
    2. Informational materials in the form of books, articles, periodicals, other written materials, audiotapes, videotapes, or other forms of communication
    3. Sample merchandise, promotional items, or tokens routinely given in business settings, including tradeshows and professional meetings
    4. Food, refreshments, or entertainment provided at events if value does not exceed $50 per occasion. Splitting costs to avoid the limit is prohibited
    5. Situations where refusal or reimbursement would harm institutional interests—employee must disclose gift details (description, estimated value, provider, explanation) within 14 days to their supervisor
    6. Meals or travel provided when the employee is a speaker or panelist at a recognized organization’s event
    7. Participation in institution or foundation fundraising and public relations activities, i.e. golf tournaments and banquets, for which conflicting parties provide sponsorships; and
    8. Loans from established financial institutions made in the ordinary course of business on usual and customary terms, so long as there are no guarantees or collateral provided by any conflicting party.
  2. Inappropriate use of students, support staff, state resources, or Intellectual Property
    1. Employees must not exploit students or staff for personal activities. Any non-institutional task beyond incidental must be disclosed and approved by HR.
    2. Employees may not make significant use of State-owned facilities, equipment, materials or other resources, not otherwise available to the public, in the course of activities which are not related to the institution and which are intended for personal benefit, without prior disclosure and approval of the institution’s chief financial officer.
  3. Failure to disclose intellectual propertyDisclosure Requirements
    1. TBR policy 5.01.06.00 Intellectual Property governs the rights and responsibilities which persons affiliated with the TBR and its institutions have regarding intellectual property developed during the term of their affiliation with the TBR.
    2. Among the responsibilities enumerated in the policy is that of disclosure of inventions and those copyrightable works which may be reasonably expected to have commercial value which they have jointly or solely developed or created during their affiliation with the TBR and its institutions.
Disclosure Requirements
1. Employees who believe a conflict of interest exists, personally or for another covered individual, must submit a written disclosure describing relevant facts to Conflictofinterest@roanestate.edu.
2. No particular format is required, but the disclosure should adequately describe the pertinent facts and circumstances.
3. Disclosures shall be submitted to the employee’s immediate supervisor or sent via email to: conflictofinterest@roanestate.edu. If submitted to the supervisor, supervisors must forward disclosures to the committee. The members of the Conflict of Interest Committee receiving these emails have been designated by the college president to receive such disclosures.
4. Disclosures made by a president shall be submitted online to the Tennessee Ethics Commission.
Special Disclosure Requirements for Certain TBR Employees – There are special disclosure requirements for researchers applying for or receiving NSF or PHS funding and also the president, coaches, assistant coaches, and employees of athletic departments who are exempt from the provisions of the Fair Labor Standards Act. Please refer to TBR policy 1.02.03.10 Conflict of Interest.
1. Presidents, coaches, assistant coaches and employees of athletic departments who are exempt from the provisions of the Fair Labor Standards Act are required to file a financial disclosure form within one month of their initial appointment and annually thereafter in January.
  1. The president of RSCC, appointed by the TBR, is required by Tenn. Code Ann.§ 8-50-501(a)(15) to file an online Statement of Disclosure of Interests Form with the Tennessee Ethics Commission at https://conflict.app.tn.gov/conflict/, Form ss-8005 (State Officials). For the presidents this Statement of Disclosure will meet the requirements of this policy.
  2. Coaches, assistant coaches, exempt employees of the athletic department are required to complete a disclosure form shall also use the Tennessee Ethics Commission Form ss-8005, Statement of Disclosure of Interest Form and accompanying instructions. The form shall be submitted to the administrative assistant to the VP of Business and Finance, who will submit to the conflict of interest committee for their review. Once the review has been completed it will be housed in the institutions’ Human Resource Office.
  3. Vice Presidents/Director of Purchasing are required to complete an Interest Disclosure form which will be submitted to the Conflict of Interest Committee.
Conflict of Interest Committee Duties/Selection
1. A Conflict of Interest Committee shall be formed from RSCC’s faculty and staff, pursuant to TBR’s policy 1.02.03.10, Conflict of Interest. The general responsibilities of this committee are defined in TBR policy 1.02.03.10. Following evaluation of the disclosure, the committee shall render a decision regarding the issue(s) presented by the disclosure. Any disclosure which indicates an actual violation of law shall be forwarded to the RSCC’s president along with the committee’s findings. Persons potentially committing a conflict of interest violation under consideration by the review committee shall receive notice of the committee’s evaluation and be given an opportunity to appear before that committee.
2. The committee shall consist of three members, with at least one member selected from the faculty and at least one member selected from administrative or support staff personnel.
  1. Members of the committee shall be selected by the president of RSCC.
  2. Members of the committee shall serve two-year terms. Members may serve multiple, consecutive terms.
  3. The committee shall meet as frequently as necessary to conduct its business but no less than once per semester.
  4. As described in TBR policy 1.02.03.10, the committee shall evaluate conflict of interest disclosures and make determinations regarding what actions may be required to manage, reduce or eliminate conflicts of interest.
Review of Disclosures - Disclosures will be evaluated by the Conflict of Interest Committee.
Sanctions - Failure to observe restrictions imposed as a result of review of conflict of interest disclosure or a knowing failure to disclose a conflict of interest may result in disciplinary proceedings under TBR and/or institutional policy.
Appeals - Decisions made by the RSCC Conflict of Interest Committee may be appealed to the president of RSCC. Decisions of the president shall be final and binding.

Revision History: 02/04/2016, 03/02/2021

TBR Policy Reference: 1.02.03.10

Revision Date Effective: 01/12/2026

Revision Approval By: Christopher L. Whaley, President

Original Date Effective: 01/20/2004

Original Approval By: Wade B. McCamey, President

Office Responsible: Vice President for Business & Finance

Reviewed: 01/12/2026

Roane State Community College

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