Disclosure and Management of Conflicts of Interest

Kentucky Technical University Corporation has adopted the LFI Conflict of Interest policy.  

Disclosure and Management of Conflicts of Interest

Should an appearance of impropriety or actual conflict of interest exist, appropriate actions must be taken, which will vary depending upon the particular facts. The employee involved in the conflict situation must work cooperatively with their manager to achieve a resolution of the conflict issues in the best interests of the foundation, as requested by the foundation. This may include the employee being removed from a position of decision-making authority with respect to the conflict situation or other more serious actions, depending upon the nature of the conflict. If the conflict involves a grant or a contract being entered into by the foundation, the due diligence review process must disclose the conflict and document the steps taken to address the conflict. A copy of this information must be provided to the Legal Team.

  1. Gifts

As a general rule, foundation employees may not receive or offer any gift or anything else of significant value for the purpose of influencing the action of the foundation or of the recipient. Gifts (except those generally valued at $100 or less) received from vendors, suppliers, consultants, and grantees as part of normal business practice must be declined or given to the foundation or shared with the foundation generally, and if acknowledgement is appropriate, acknowledged on behalf of the foundation. This guideline is not intended to prohibit normal business practices, such as meetings over meals, corporate items given to participants in meetings and conferences, or token hosting gifts, as long as they are of nominal and reasonable value and promote the foundation’s legitimate business interests. If an employee believes there is an appropriate reason to make an exemption to this policy for an individual situation, he or she should contact the Legal Team prior to giving or accepting the gift.

  1. Director’s Fees, Honorariums, Expense Reimbursements, and other Similar Payments

Staff members are encouraged to undertake speaking engagements, serve on boards and write articles, provided the time for such activities does not interfere with the employee’s foundation responsibilities. Director’s fees, author’s royalties, honorariums, and payments for published articles or speaking engagements should only be accepted, however if: (1) the materials prepared and all activities undertaken in connection with these activities are prepared or conducted on personal time, (2) the issues addressed are not related to the foundation’s activities or mission, (3) foundation resources are not utilized, and (4) the organization making the payment is not a foundation grantee. If an employee believes an exceptional circumstance merits an exception to this policy, the employee should consult the Legal Team for advice and appropriate documentation. Travel costs and expenses incurred in connection with any activities that are not foundation related must be borne by the individual or the organization inviting the individual to participate in the activity and should not be paid or reimbursed by the foundation.

  1. Accepting Compensated Work Outside the Foundation

Officers, Directors and Staff must report additional positions they accept for compensated work to the Secretary before performing additional activities outside of the foundations scope.

  1. Political Activities

The foundation is strictly prohibited from engaging in electoral politics or lobbying activities. Foundation employees are free to engage in these types of political activities on a personal basis provided the activities do not conflict with their ability to carry out their foundation responsibilities or create confusion between positions or actions that are taken by them personally versus as a foundation representative. Before a foundation employee becomes actively involved in a political campaign or activity, the employee should discuss with the Legal Team appropriate actions to avoid or minimize the risk of the employee’s personal actions being attributed to the foundation and also review any other unintended potential impacts such activity could have on the foundation. Individual political activities should only occur during off-duty hours, at the employee’s own expense, and without use of the foundation’s name, resources, facilities, or equipment. If an employee is asked to sign political advertisements or endorsements that include employment, a generic description should be used such as “foundation program officer” or “grant maker in education” rather than including the name of the foundation. Only the Co-Chairs of the foundation can authorize the taking of any position by the foundation on legislation, referenda, or the like.

  1. Competing for Foundation Individual Scholarships, Fellowships, or Awards

Employees of the foundation and their family members may not compete for foundation supported scholarships, fellowships, or awards including hardware.

  1. Conflict of Interest Questionnaire

Upon commencement of employment and annually thereafter, all employees must complete a “Conflict of Interest Questionnaire.” Employees are also required to update the Conflict of Interest Questionnaire whenever there has been a change in the employee’s affiliations. Employees must disclose all of their affiliations, as requested by the form, even if there is no current conflict of interest.

  1. Interpretation

This policy cannot describe all conflicts of interest situations that may arise involving the foundation. Therefore, foundation employees must use good judgment to avoid any appearance of impropriety. Appropriate circumstances may also justify exceptions to the application of the policy. If you have any questions about this policy or its application, please err on the side of caution and transparency and seek advice from the Legal Team prior to entering into such transaction.


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