Administrative Policies

Key Personnel Conflict of Interest Policy

1. Purpose

This policy governs conflicts of interest of key personnel to ensure that KCTCS conducts its activities with integrity and transparency.

2. Scope

This policy applies to key personnel employed by KCTCS to include executive level employees and major management personnel.

3. Definitions

1. Key Personnel: a KCTCS employee who makes decisions on behalf of KCTCS, or an employee with the capacity or the appearance of the capacity to influence decisions made on behalf of KCTCS. These employees include but are not limited to the KCTCS President, College Presidents, System Office Cabinet members, members of the College Presidents’ leadership teams, college and KCTCS foundations executive directors, and all college and KCTCS procurement employees.
   
   
2. Conflict of Interest: a conflict of interest exists if key personnel:
   1. engages in acts that conflict with their job responsibilities; KCTCS’ interests as stated or implied; or clearly contradicts a goal, objective, or other educational, fiscal, or legal agenda of KCTCS; or
      
      
   2. has existing or potential financial or other interests that impair or reasonably appear to impair their judgment in the discharge of their job responsibilities; or
      
      
   3. is or has a family member who is an officer, director, employee, member, partner, trustee, or controlling stockholder of any organization that has such existing or potential financial or other interests.
      
      
3. Family Member: spouses, partners, parents, siblings, children, and any other relative if the relative resides in the same household as the key personnel.

4. Policy

1. Annual Disclosure: Key personnel shall complete the Conflict of Interest form on an annual basis and file with the Office of General Counsel. This annual disclosure is required for all key personnel, even if there are no conflicts to disclose. This form will be filed in the employee’s electronic personnel file.
   
   
2. Continuous Disclosure: In addition to the annual disclosure, key personnel shall have a continuous duty to update the Conflict of Interest form. If a conflict arises throughout the year that was not already disclosed, key personnel shall file an updated Conflict of Interest form with the Office of General Counsel.
   
   
3. Noncompliance: Failure to complete the annual disclosure, to update the Conflict of Interest form when a new conflict arises, or intentional violations of the policy, procedure, and statutes may lead to discipline up to and including termination.

5. Procedure

KCTCS Administrative Procedure 5.1.20-P implements this policy.