5.2.3 Consulting & Other Outside Activities

Policy Section: Conditions of Employment

Policy Number and Title: 5.2.3 Consulting & Other Outside Activities
Applicable to: All Administrative & Support Staff Employees
Effective Date: January 12, 2009
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Supervisor Responsibility

To ensure that employees understand the importance and requirements of this policy and complete the annual staff disclosure form and that there is adequate and timely review, supervisors should:
Nonadherence
Not adhering to this policy is considered a serious matter and may result in disciplinary action, up to and including the termination of employment.
Confidentiality
All materials will be kept confidential by the supervisor. In the event of exceptional circumstances, material will be made available to the Office of Human Resources, the Office of General Counsel and the Office of Audit and Compliance.

Annual Disclosure Form

Conditions for Disclosure
To protect the employee as well as the University should future allegations of conflict of interest arise, an annual disclosure is required of all administrative and support staff in administrative and academic departments to disclose any of the following conditions:
  1. The employee has worked as an employee, independent contractor or consultant (paid or unpaid) for any organization other than Princeton University.
  2. The employee has a management or other fiduciary role in any organization other than Princeton that includes, but is not limited to service as an officer, board of director or supervisor or manager. It also includes any type of scientific, technical, advisory or other board appointment.
  3. The employee or persons related to the employee by blood, marriage or civil union, or members of the same household, including domestic partners, or persons with whom the employee has a personal relationship has a significant financial interest in an organization or enterprise, other than Princeton University. A significant financial interest includes but is defined as greater than one percent of such organization’s stock, profits, or assets.
  4. The supervisor considers it appropriate, given the nature of the work of the section or department, to require all staff members in positions where the possibility for conflict of or the appearance of conflict exists to complete a disclosure form.
  5. The employee perceives any risk of conflict of interest or a serious appearance of conflict of interest in performing the University job duties, due to any consulting, employment or other outside activities.
Disclosure Form
All circumstances as described above must be reported to the employee's immediate supervisor using the Conflict of Interest & Conflict of Commitment — Annual Disclosure Form.
 
Clearly, reaching some arbitrary threshold does not imply that a conflict (or even a potential conflict) of interest exists, but requiring disclosure under these conditions can be viewed as a type of safety net, a cost effective "insurance policy" for both the employee and the supervisor. The supervisor should review the disclosure form with the employee and confirm that no potential for conflict exists. 
Resolving the Situation
If there is a potential conflict, the supervisor should decide how best to resolve the situation. If the employee disagrees with the supervisor's judgment or if the supervisor needs additional guidance, the relevant party or both parties should state the reasons for their concern and refer the situation to the department head.
 
If the situation warrants, the department head will refer the situation to the Vice President for Human Resources.

Related Documents

Other Policies
 
 
 
 
 
 
 

Contacts

Office of Human Resources
(609) 258 – 3300
 

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