AGENDA



BOARD OF REGENTS AUDIT COMMITTEE



November 5, 2004

11:00 a.m. - 12:00 noon

Morgan 204





1. Approval of Minutes of October 12, 2004 Meeting



2. Washburn University Fiscal Year 2003-04 Annual Audit - Brad Koehn, Berberich Trahan



3. Board of Regents Conflict of Interest Policy and Annual Conflict of Interest Disclosure Statement and University Conflict of Interest Policy and Annual Conflict of Interest Disclosure Statement



4. Annual Audit RFP and Timeline



5. Other Issues



6. Next Meeting



7. Adjourn



AGENDA ITEM 1.



Minutes of October 12, 2004 Audit Committee Meeting



WASHBURN UNIVERSITY BOARD OF REGENTS

Audit Committee Meeting

October 12, 2004



Regents Present: Nancy Paul, Chair, Maggie Warren, Lewis Ferguson, Blanche Parks



Staff Present: Jerry Farley, Wanda Hill, Denise Ottinger, Rhonda Thornburgh, Tom Ellis



Also Present: Mary Lou Herring



Minutes of the May 13, 2004 meeting were approved as distributed.



Conflict of Interest Policy and Annual Disclosure Statement -

The revised drafts were reviewed. Regent Paul shared a suggestion from Board Chairman Roth to submit disclosure of potential conflicts of interest to the board secretary rather than the board chair. The committee addressed potential conflicts that may arise during the year, after the original statement has been filed. An additional declaration will be added, putting the responsibility on board members to inform the board when they become aware of a potential conflict or perceived conflict. The statement is to be filed by August 1st each year or within 30 days of appointment.

The conflict of interest policy should be on the agenda of every new board member orientation.

At the beginning of every board meeting the question should be asked whether anyone has a potential conflict with anything on the meeting agenda. Board members will be asked to abstain from voting on issues where there is a conflict or a perceived conflict.

It was moved and seconded to approve the regents conflict of interest policy and disclosure statement, as modified, and recommend to the board for approval.

Outside consulting was discussed.

It was agreed to mirror the employee policy and disclosure statement after the corrected regents policy and statement. It was moved and seconded to approve the University conflict of interest policy and disclosure statement, as modified, and recommend board approval.

The modified documents will be sent to the board for review prior to the next board meeting.



Annual Audit RFP -

The University is in the fourth year of a four year agreement with auditors, Berberich Trahan.

The committee agreed a request for proposal should be sent out for audit services. The RFP will be issued November 10, with the bids due on December 14. A recommendation will be submitted at the January 14 board meeting.

President Farley said it is important for the committee to be actively involved in the decision to hire the auditor. It was agreed the RFP will be submitted in the same manner as in the past and the committee will review the proposals and make a recommendation to the board.

A question was asked whether BKD, LLC could bid on the audit services since they were engaged by Washburn to do the internal control review for the University. Regent Paul indicated since it was a defined engagement that has been completed there is no conflict in their bidding on the audit services. If a follow-up review is needed on internal controls it will be re-bid.



Risk Management Program -

The audit committee is assigned the responsibility of reviewing the University risk management program. President Farley noted there are many broad areas of risk management which involve considerably more than just buying insurance. All risks cannot be eliminated but we can attempt to manage them by identifying potential losses and evaluating the best way to handle the risk. Some of the things the University is doing to manage risks on campus include:

hiring a full-time safety officer to oversee hazardous waste disposal and various compliance issues (i.e., OSHA, EPA), and to provide training on life safety issues to students and employees;

developing a crisis management plan for the University;

provide emergency back-up generators for the computer system, KTWU, and Police Department; and

compliance efforts regarding discrimination and ADA issues.





The next Audit Committee meeting is scheduled for November 5, 2004 at 11:00 a.m. in Morgan 204.



Meeting was adjourned.





AGENDA ITEM 2.



Washburn University Fiscal Year 2003-04 Annual Audit Report



Brad Koehn will hand out and discuss a "draft" of the audit report



AGENDA ITEM 3.



Board of Regents Conflict of Interest Policy and Annual Conflict of Interest Disclosure Statement



University Conflict of Interest Policy and Annual Conflict of Interest Disclosure Statement



Final review and discussion prior to recommending to Board of Regents for approval





WASHBURN UNIVERSITY BOARD OF REGENTS

CONFLICT OF INTEREST POLICY



The Board of Regents recognizes that honesty, integrity, accountability, responsibility, openness and disclosure of financial relationships and interests are absolutely essential to the educational process and administration of the University. The Board deems it necessary and appropriate for the University to provide an atmosphere in which the highest standards of behavior, accountability and responsibility are inculcated among students, faculty, administrators and regents. To achieve this end, the Board has adopted a conflict of interest and disclosure policy for all employees of the University.



Board members of Washburn University serve the public trust and have a clear obligation to make decisions solely on the basis of a desire to advance the best interests of the University and the public good. The integrity of the University must be protected at all times.



Recognizing the Board should provide leadership by example, it is the purpose of this policy to ensure objectivity, integrity, and confidentiality on the part of the regents. All regents should identify and avoid actual conflicts of interest, and the appearance of a conflict of interest. The Board unanimously agrees in order to prevent any potential conflict of interest between regent responsibilities and outside activities from arising, no regent shall participate in an action where he or she is financially interested either directly or indirectly through business, investment, or family in any contract or transaction affecting the interest of the University, nor procure or be a party in any way to procuring the appointment of any relative to any position of trust or profit connected with the University. In addition, there should be proper disclosure of those matters where a conflict of interest arises, or where a potential conflict could theoretically arise. Full disclosure of any situation in doubt should be made so the Board may make an impartial and objective determination of whether a conflict exists.



Thus, the Board requires each regent annually (a) to be familiar with the terms of this policy; (b) to disclose on the annual conflict of interest disclosure statement any possible personal, familial, or business relationships that reasonably might give rise to a conflict or a perceived conflict involving the University; and (c) to acknowledge by his or her signature that he or she is in accordance with the letter and spirit of this policy. If a regent becomes aware of a potential or perceived conflict of interest subsequent to filing the annual statement, the regent must report this event to the secretary of the Board of Regents.

If a regent is uncertain whether to list a particular relationship, the board chair and the board secretary should be consulted.

The following definitions are provided to help regents decide whether a relationship should be disclosed:

Business Relationship: One in which a regent, or a member of his or her family as defined below serves as an officer, director, employee, partner, trustee, or controlling stockholder of an organization that does substantial business with Washburn University.

Family Member: A spouse, parent, sibling, child, grandchild, or any other relative if the latter resides in the same household as the regent.

Substantial Benefit: When a regent or a member of the regent's family (a) is the actual or beneficial owner of more than 5 percent of the voting stock or controlling interest of an organization that does substantial business with the University, or (b) has other direct or indirect dealings with such an organization from which the regent or a member of the regent's family benefits directly, indirectly, or potentially from cash or property receipts totaling $10,000 or more annually.

Regents who have declared a conflict of interest, or who have been found to have a conflict of interest, shall refrain from participating in consideration of proposed transactions unless the Board requests information or interpretation for special reasons. Should a conflict of interest matter require a Board vote to resolve, those concerned shall not be present at the time of the vote.



Each Board of Regents' member shall receive a copy of this conflict of interest policy and agree to comply with the policy by executing a conflict of interest disclosure statement no later than August 1 each year, or within 30 days of appointment to the Board, and sending it to the secretary of the Board of Regents. Each Board of Regents' member shall also notify the secretary of the Board of Regents of any perceived or potential conflict of interest which might arise subsequent to filing the annual conflict of interest disclosure statement.



WASHBURN UNIVERSITY BOARD OF REGENTS

ANNUAL CONFLICT OF INTEREST DISCLOSURE STATEMENT



I have read the Washburn University Board of Regents Conflict of Interest Policy and understand its provisions, and hereby provide the following information (attach additional pages as necessary):



10. Are you aware of any business or personal relationships between Washburn University and yourself, your firm or a member of your family as defined by the letter or spirit of this policy that may represent a conflict of interest?



Yes
No

If Yes, please list such relationships, with whom the relationships exist, and the

details of annual or potential financial benefit as you can best estimate them.





11. List any organization or business in which you or a member of your family currently serve (or have served during the last twelve months) as a member, director, trustee, officer, partner or agent of or for the organization or business, irrespective of the amount of compensation received for holding such position (if none, write "None"):





Business Name and Address Position Held Held by Whom












12. List any person or business from whom you or a member of your family have received gifts, loans or honoraria from any source from which the University buys goods or services or otherwise has significant business dealings in the preceding twelve months (if none, write "None").





Name of Business or Person Address Received by:


DECLARATION:





I, _______________________________, declare that this conflict of interest disclosure (including any accompanying pages and statements) has been examined by me and to the best of my knowledge and belief is a true, correct and complete statement of all my economic interests and other matters required by the conflict of interest policy.







DECLARATION OF INTENT:





I declare that I will notify the secretary of the Board of Regents of any perceived or potential conflict of interest which might arise subsequent to filing this annual conflict of interest disclosure statement as required by the conflict of interest policy.









___________________ ______________________________________

Date Signature





Return your completed statement to the Secretary, Washburn University Board of Regents, no later than August 1 or within 30 days of being appointed to the Washburn University Board of Regents.



13. CODE OF ETHICS, STANDARDS OF CONDUCT, AND CONFLICT OF

INTEREST



13.1. Purpose



0.0.1 The University recognizes that honesty, integrity, accountability, responsibility, openness and disclosure of financial relationships and interests are absolutely essential to the educational process and administration of the University.

0.0.2 The University administration deems it necessary and appropriate for the University to provide an atmosphere in which the highest standards of behavior, accountability and responsibility are inculcated among students, faculty, administrators and regents.

1.2. CODE OF ETHICS AND STANDARDS OF CONDUCT

Adherence to the highest standards of professionalism, honesty, integrity, ethical conduct, and fairness by University personnel is essential to ensure proper performance of University business, including teaching, research, public service, and other business activities, and the maintenance of confidence in the University by its constituents. The professional conduct of each member of the campus community is expected to be beyond reproach and consistent with and fully comply with these principles. All members of the campus community are expected to engage in the following:



(a) Trustworthy conduct - including professionalism, teamwork, fairness, dependability, honesty, and integrity in communications and actions.

(b) Respectful behavior - treating everyone with respect, civility, courtesy, tolerance and acceptance, and recognizing the worth, dignity and unique characteristics of each individual.

(c) Accountability - taking personal responsibility for one's actions and decisions.

(d) Fair and just actions - employing good judgment and ethical behavior in decision making, never inducing or compelling others to take part in unethical, improper or illegal conduct.

(e) Compassion - caring for others, both within and apart from the Washburn community, and providing the highest quality service to the campus community.

(f) Good citizenship - striving to make the Washburn community function well now and in the future.

(g) Responsible management - following the rules, adhering to all University policies and procedures, regulatory agency requirements, federal and state laws, and professional standards, including prudent use of University resources in a fiscally responsible manner.





0.3. CONFLICT OF INTEREST



A conflict of interest exists in any situation in which financial or other personal considerations may compromise, or have the appearance of compromising, an individual's judgment in the performance of administration, management, instruction, research, public service, or other professional activities for and/or on behalf of the University.



To ensure continued confidence in the University and its personnel, University officers, deans, directors, and other individuals acting on behalf of Washburn University have an obligation to avoid conflict, or any appearance of conflict, between their personal interests and the interests of the University in dealing with any organization or individual having, or seeking to have, any business relationship with the University, or any organization or individual whose objectives or interests may be adverse to the specific interests of the University. Conflict of interest situations, or the appearance of conflicts of interest, have the potential to result in serious harm and direct losses to the University. The losses are often difficult to detect and include not only direct monetary losses and loss of confidence in the University, but also negative publicity and erosion of employee morale.



It is the policy of the University that its officers, faculty, staff, and others acting on its behalf shall faithfully discharge their duties and shall avoid ethical, legal, financial, or other activities incompatible with the impartial, objective and effective performance of their responsibilities and ensure their activities and interests do not conflict with their obligation to the University or to its welfare. They shall not knowingly use University property, funds, position or power for personal or political gain. They shall inform their supervisors in writing of reasonably foreseen potential conflicts.



This policy applies to all University officers and employees, and to

persons affiliated or associated with the University.



This policy is to be interpreted and applied in a manner that will best serve the interests of the University and that distinguishes between those minor and inconsequential conflicts which are unavoidable and those conflicts which are substantial and material. A conflict of interest may exist when an individual, his or her close relative, or a person or organization with whom the individual is associated has an existing or potential financial or other interest which involves the individual's University responsibilities. If an individual believes he or she may have a conflict of interest, he or she shall promptly and fully disclose the conflict to the appropriate supervisor or officer and shall refrain from participating in any way in the matter to which the conflict relates until the conflict question has been resolved. In some cases, it may be determined after full disclosure, the University's interests are best served by participation of the individual despite the conflict or appearance of a conflict.



The policy does not prohibit an individual from freely pursuing those teaching, research, and professional and public service activities which will not result in such a conflict, nor prohibit an individual from accepting pay, compensation, fees, honoraria, or reimbursement of expenses which may be offered in connection with such activities.



Conduct by an employee that violates the University's policies, regulations or rules pertaining to conflict of interest shall constitute a breach of the employment contract and subject the employee to disciplinary action including suspension from or termination of employment.



It is the responsibility of each supervisor to ensure individuals under his or her supervision are familiar with the policies and procedural requirements of their positions, and that they are apprised of any new or revised requirements on a timely basis.



All persons involved in projects receiving federal funds shall consult applicable federal laws and regulations and comply with conflict of interest rules which may govern federal grants or contracts or other sponsored agreements.



WASHBURN UNIVERSITY

ANNUAL CONFLICT OF INTEREST DISCLOSURE STATEMENT



I have read the Washburn University Conflict of Interest Policy and understand its provisions, and hereby provide the requested information (attach additional pages as necessary). The following definitions are provided to assist in completing the annual disclosure statement:



Business Relationship: One in which a University employee, or a member of his or her family as defined below, serves as an officer, director, employee, partner, trustee, or controlling stockholder of an organization that does substantial business with Washburn University.

Family Member: A spouse, parent, sibling, child, grandchild, or any other relative if the latter resides in the same household as the University employee.

Substantial Benefit: When a University employee or a member of the employee's family (a) is the actual or beneficial owner of more than 5 percent of the voting stock or controlling interest of an organization that does substantial business with the University, or (b) has other direct or indirect dealings with such an organization from which the employee or a member of the employee's family benefits directly, indirectly, or potentially from cash or property receipts totaling $2,000 or more annually.





1. Are you aware of any business or personal relationships between Washburn University and yourself or a member of your family as defined by the letter or spirit of this policy that may represent a conflict of interest?



Yes
No

If Yes, please list such relationships, with whom the relationships exist, and the

details of annual or potential financial benefit as you can best estimate them.















2. List all current places of employment (or those held during the last twelve months), and any businesses from which you, your spouse or a member of your household received $2,000 or more in compensation (salary, director fees, thing of value, or economic benefit received in return for services rendered, or to be rendered), which was reportable as taxable income (if none, write "None"):





Business Name and Address Position Held Held by Whom




3. List any organization or business in which you or a member of your family currently serve (or have served during the last twelve months) as a member, director, trustee, officer, partner or agent of or for the organization or business, irrespective of the amount of compensation received for holding such position (if none, write "None"):





Business Name and Address Position Held Held by Whom




4. List any person or business from whom you or a member of your family have received gifts, loans or honoraria from any source from which the University buys goods or services or otherwise has significant business dealings in the preceding twelve months (if none, write "None").





Name of Business or Person Address Received by:






DECLARATION:





I, _______________________________, declare that this conflict of interest disclosure (including any accompanying pages and statements) has been examined by me and to the best of my knowledge and belief is a true, correct and complete statement of all my economic interests and other matters required by the conflict of interest policy.







DECLARATION OF INTENT:





I declare that I will notify University Legal Counsel of any perceived or potential conflict of interest which might arise subsequent to filing this annual conflict of interest disclosure statement as required by the conflict of interest policy.









___________________ ______________________________________

Date Signature





Return your completed statement to the Office of University Counsel no later than September 1 or within 30 days of being appointed to your position with the University.

















































BAFAH Administrative Regulations and Procedures



The following regulations and procedures apply to the Washburn University Conflict of Interest Policy



4.a. Types of Conflict



4.b. Personal Gain from University Positions



4.b.i. No employee or individual working for or on behalf of the

University may use or attempt to use, in a manner

contrary to the interests of the University, his or her position

or University property or services, to gain or attempt to gain anything for his or her private benefit or to benefit a member of his or her family.

4.b.ii. No employee or individual working for or on behalf of the University can act as an agent representing any manufacturer, publisher, business house, or corporation to sell or dispose of any apparatus, books or other merchandise required for instruction, research, or service whether or not he or she receives compensation.

4.b.iii. No employee or individual working for or on behalf of the University may directly or indirectly solicit, receive, accept, or agree to receive a gift or thing of value from any persons or organizations associated with or seeking association with the University by inducing the reasonable belief that the giving of the thing will influence his or her performance or failure to perform any official action. For purposes of this policy a gift is defined as lodging, transportation, personal services, a gratuity, subscriptions, membership, trip, loan, extension of credit, forgiveness of debt, advance or deposit of money, or anything of value. For purposes of this policy a gift shall not include:

Food or beverage consumed at a single meal or event, provided the value is reasonable under the circumstances but in no event exceeds $100 per person;

Food, beverages, and registration at group events to which substantial numbers of University employees and/or its volunteers are invited;

Promotional items generally distributed to the general public;

Textbooks, software, and instructional materials to be reviewed by teaching faculty; an award, plaque, certificate, memento, or similar item given in recognition of the recipient's civic, charitable, political, professional, private or public service or achievement.

4.0.1. No employee or individual shall use confidential information acquired in connection with University-related activities for personal gain for themselves or unfair advantage for another person, or for other unauthorized purposes.

4.0.2. An employee shall not purchase surplus University-owned property absent a fair and open bidding process.



4.1. Contracting and Leasing



The reporting requirements and limitations set forth apply to all contracts except those which create or supplement employment relationship agreements between the University and the employee. Those items covered, but are not limited to, the purchase of equipment, goods and supplies, contracts for construction, renovation and repair, leases and rentals, and contracts for professional services.

4.1.1. No employee or individual may recommend the University enter into any contract or lease without providing prior written disclosure of the nature and extent of any relationship he or she may have with the vendor/lessor to the appropriate administrator. The decision to enter into a contract or lease shall take into consideration any interest in such contract or lease held by the employee or a member of the employee's family. A contract or lease may only be entered into if it is deemed to be in the best interests of the University and any employee's interest will not conflict substantially or materially with his or her discharge of University responsibilities.

4.1.2. No employee may contract with the University to provide a service which is the same as or similar to the service the employee provides as a University employee. Such services may be provided only as a University employee in the course of University employment.

4.1.3. Neither the University nor any of its employees should benefit financially from the sale of materials developed solely for sale to Washburn University students (e.g., course packs); however, it is understood royalties might accrue from materials developed for sale to an audience broader than Washburn University students. University employees may not retain royalties from the sale of intellectual property (e.g., textbooks, tapes, software or other materials) to Washburn students that is authored by the employee if either of the following conditions are met: students purchased the materials in conjunction with a course taught by the employee who will earn the royalties, or the employee who will earn the royalties was involved in selecting the materials students are expected to purchase. Royalties accruing from the sale of these materials to Washburn University students will be given to the employee's dean's office to be used directly or indirectly to encourage and support more research and creative endeavors within the college or school.

4.1.4. An employee or a member of an employee's family cannot have an interest in any organization that is in direct competition with a service provided by the University.



4.2. Supplemental Employment/Outside Activities



The University recognizes many of its employees have specialized skills or areas of expertise, and the utilization of these skills in "outside activities" can be beneficial to both the individual and the University. Such activities may include, but are not limited to: teaching and consulting; personal and/or professional involvement in the community, in professional organizations, and in state or local politics; and any employment or employment-related activities undertaken to supplement current income.



The University respects the rights of an employee to engage in activities of his or her choice, both within and outside the University, as long as those activities do not constitute a conflict of commitment. Conflicts of commitment are situations in which a University employee's supplemental or additional activities, often valuable in themselves, and even when they result in no personal gain or improper advantage to others, nevertheless interfere improperly with the employee's obligations to the University or prevent the employee from fulfilling the requirements of his or her position. Conflict of commitment may also arise when an employee accepts more than the equivalent of one full-time appointment. As a general policy, a full-time employee of Washburn University should not have another employment obligation during the normal working hours that he or she is compensated for by the University.



Certain general policies and procedural guidelines, described below, have been adopted to avoid conflict of interest situations.



4.2.1. Employees are permitted to engage in outside consulting activities and other outside activities provided the employee meets his or her obligation to the University and complies with any applicable provisions of a collective bargaining agreement, if applicable, concerning outside employment.

4.2.2. An employee shall not accept any outside position that would impair the employee's ability to fulfill the employee's obligation to the University since an employee's primary work commitment is to his or her full-time position at Washburn University.

4.2.3. A full-time employee with faculty rank shall not take on a teaching assignment in another post-secondary educational institution during the academic year except after obtaining written approval of the Vice President for Academic Affairs.

4.2.4. An employee shall not engage in outside employment or activities which could be viewed as impairing the employee's judgment in the performance of University duties and responsibilities.

4.2.5. An employee cannot utilize University materials, facilities, or other resources in order to engage in outside employment or other activities.

4.2.6. An employee cannot exploit students, volunteers, or other University employees for the benefit of any external activity of the employee.

4.2.7. In all employment activities outside his or her Washburn University employment, the employee functions in his or her individual capacity and without the support of the University, and is solely responsible for his or her acts as the University assumes no responsibility for the activity.



4.3. Use of University Assets and Resources



Sound business conduct requires each employee and individuals working for or on behalf of the University, as a basic condition of service, to assume responsibility for safeguarding and preserving the assets and resources of the University, particularly those for which he or she is responsible. All users of technological and information resources are responsible for protection of University assets and for the accuracy, integrity, and confidentiality of the information to which they have access. Resources are not to be abused or utilized in such a way as to interfere with, or cause harm or damage to, another person, institution, or company within or outside the Washburn University community.



The following statements serve to remind us of these basic commitments and responsibilities.



4.3.1. No individual shall use the official title of the University or any of its parts, in whatever form that title may appear, or any of the University's graphic identification symbols except in connection with legitimate University purposes.

4.3.2. The University's name, facilities, equipment, supplies, personnel and other resources are to be used only for the furtherance of the University's mission. No individual or employee shall make unauthorized use of any University resources, including the services of University employees, students, or volunteers, for the personal benefit of the individual or the individual's family (arising as a result of an individual's or employee's private business, outside employment, or consultation for a fee), or for any unlawful or improper purpose.

4.3.3. Official University stationery may be used only for conducting business for or on behalf of the University and not in conducting outside business, personal use, or other private or political activities of any person or entity.

4.3.4. No employee or individual may list a University address, phone number, fax number or electronic mail address on stationery, business cards, advertisements, etc. as a contact for their private business, outside employment, or consultation for a fee, or for any personal use.

4.3.5. All revenues generated by the University, and all expenditures for goods and services, must be recorded and accounted for within the financial accounting system of the University.

4.3.6. No false or artificial entries are to be made in the accounting records of the University for any reason.

4.3.7. No payment on behalf of the University is to be approved or made with the understanding that any part of such a payment is to be used for any purpose other than that described by the documents supporting the payment.

4.3.8. No cash advance is to be approved with the understanding that any part of such advance is to be used for any purpose other than for authorized University purposes.

4.3.9. No individual or employee, or group of individuals or employees, shall circumvent University internal control procedures.

4.3.10. No employee or individual shall prepare or participate in preparing false or misleading reports or information to be presented to internal or external constituents.

4.3.11. No unrecorded or undisclosed bank accounts are to be established by any individual, department or organization to fund, or to assist in funding, any authorized University activity.

4.3.12. No person in a supervisory or management position is to use the authority of his or her position to assign an individual to perform functions or tasks unrelated to performing University business.

4.3.13. No individual may use the University's tax exempt number to purchase goods or services for other than official University business.



5. Disclosure and Consultation



The following procedures apply except in situations where a procedure is otherwise provided by a collective bargaining agreement.

5.1. When it appears a material conflict may arise between the personal interests of an individual and his or her responsibilities to the University, he or she shall notify the appropriate supervisor or officer by submitting a written statement describing the nature of the possible conflict. If an apparent conflict comes to the attention of the supervisor, he or she may request a written statement from the individual.



5.2. If an individual is in doubt as to whether he or she is confronted with a potential conflict of interest, the individual should consult with the appropriate supervisor or officer to determine if the outside interest could conflict impermissibly with the individual's obligation to the University.



5.3. The appropriate supervisor or officer shall promptly notify the individual in writing that: (1) there is no conflict and he or she may proceed; or (2) there may be a conflict and further consultation is necessary prior to reaching a determination; or (3) there is a conflict and the individual shall not proceed with his or her personal interest which resulted in the conflict. A copy of such notification shall be send to the Vice President for Academic Affairs and the Vice President for Administration.



5.4. The individual may appeal the supervisor's or officer's decision to the President.



6. Annual Disclosure



All University officers, deans, directors, and those employees or individuals designated by the President because of their respective duties and responsibilities are to disclose to the University, on an annual basis, all business interests, affiliations, and/or relationships that could reasonably give rise to a conflict of interest involving the University.



Annual Conflict of Interest Disclosure Statements are to be distributed by the Office of University Counsel to all University officers, deans, directors, and those employees and individuals designated by the President. The University Counsel is responsible for ensuring all distributed statements are completed and returned to that office each year.



7. Enforcement

Enforcement of University policies on conflicts of interest is the ultimate responsibility of the President and the Board of Regents, who may delegate that responsibility to other University officials.



Violations of University policies on conflicts of interest, including the failure to file timely disclosures; filing incomplete, erroneous, or inaccurate disclosures; or failure to comply with prescribed procedures for managing or resolving conflicts of interest, will be dealt with in accordance with applicable University policies and procedures. The violation shall constitute a breach of the employment contract and subject the employee to disciplinary action including suspension from or termination of employment.



AGENDA ITEM 4.











Annual Audit RFP and Timeline











Final version of RFP to be released November 10, 2004


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