Q. Who is required to participate in the annual written disclosure program?
A. The roster of employees is determined by the President and Senior Cabinet. It includes nearly 500 employees throughout all divisions of the University. You will be notified if you are required to complete an annual disclosure form.
Q. Is it mandatory?
A. Yes. If you have been selected to complete an annual disclosure form you are required to do so. Regular reporting will be made to each division Vice President regarding the completion rate of those in their division.
Q. Why is this necessary?
A. The University’s Board of Trustees adopted a formal Conflict of Interest Policy in 2008 that requires annual disclosures from select employees. Such policy was adopted in accordance with expectations established by the Internal Revenue Service governing non-profit, tax-exempt organizations
Q. If I filled out a form last year and nothing has changed, do I have to fill out another one?
A. Yes. The annual disclosure process is designed to formally capture all matters occurring since the last annual disclosure and those matters that are still on-going.
Q. When is the disclosure form due?
A. June 1, 2017
Q. What if I don't have access to a computer?
A. Although electronic submission is strongly encouraged, you may submit a hard copy. Call X 5379 to request a hard copy be sent to you.
Q. Will there be any open forums available for employees to ask questions about filling out the disclosure form?
A. Not this year. Due to the low turnout/interest in the forums provided in the past, OGC will field any questions directly. Call X5379 to make arrangements to speak with one of the university attorneys for assistance in completing your form.
Q. Who will see my disclosure?
A. The Vice President responsible for the Division of Service to which you are assigned, the office of General Counsel, and when applicable, the Provost and/or President.
Q. Will my disclosure be kept confidential?
A. All disclosures are made in confidence and every effort will be made to protect the confidentiality of the disclosure. Such disclosures may, however, be shared with your supervisor and others where necessary to meet the requirements of the Conflict of Interest Program and Policy.
Q. Can you give me an example of a sample disclosed conflict?
A. Remember – “If in doubt, don’t leave it out”. Disclosure protects both you and the University. The Conflict of Interest Policy provides a number of examples of potential conflicts.
Provide as much information as is necessary to describe the conflict or potential conflict. Some brief examples include the following:
"X Company offered 4 tickets to a Red Sox game to our department in appreciation for a big order we placed. My boss offered them to me and I took my family."
"My son-in-law was recently hired after a University search and currently works in Student Affairs. I work in Public Safety" (Although this is not a conflict per se, it is a relationship the Vice President/Dean and Cabinet should be advised about.)
"I have a repair/consulting/real estate business I operate out of my home on nights and weekends."
“I occasionally use my office phone or computer or other equipment for personal use, but the use is minimal and does not interfere with my work.”
"I manage a department and hire my son/daughter each summer to work part time. S/he does not report directly to me."
"My son/daughter is a student at RWU. I work in the Bursar's/Registrar's/Student Affairs office but do not post to or access his/her records."
“I was invited out to lunch by a vendor for the University and the vendor paid the bill.”
“A University vendor that I hire as part of my University position offers me complimentary services for my house.”
Q. I work in an area where University services are available for employee use (i.e. use of rec center or library services) and I utilize those services in accordance with university policy, is this an item that should be disclosed?
A.No. If, for example, you work in the library and use your ID or library card to take books out of the library, you do not need to include this in your disclosure.
Q. Are all conflicts forbidden?
A. No, but such must be properly disclosed, evaluated and approved by senior management to ensure controls are in place to manage and monitor the conflict.
Q. How is "immediate family" defined?
A. Immediate family for purposes of filling out the disclosure is defined as your spouse, or domestic partner (consistent with University health benefits policy and procedure) and dependent children, including stepchildren.
Q. I have other questions that are not answered here, who can I contact to answer them?
A. Contact the Office of General Counsel at X5379 and a representative will assist.