Canisius College

a. In General.  Canisius College employees have a duty to avoid entering into financial, business or other relationships that conflict with the interests of the College or interfere with the performance of their professional duties. Generally speaking, a conflict of interest arises when a College Representative’s personal interests or financial affairs interfere with his or her professional judgment or job performance.

b. Specific Criteria. A conflict of interest may occur when an employee’s affiliation with an external organization meets any one of the following criteria:

i. The employee is an officer, director, partner, trustee, employee, advisory board member, or agent of an external organization or corporation providing goods and services to the college.

ii. The employee is the actual or beneficial owner of more than five percent (5%) of the voting stock or controlling interest of such organization or corporation or voting stock of such organization or corporation that exceeds $10,000 in value as determined by reference to public prices or other reasonable measures of value.

iii. The employee has dealings with such organization or corporation from which he or she expects to receive salary, royalties or other payments of more than $10,000 during the next twelve months.

iv. The employee's immediate family (spouse, parents, parents-in-law, siblings, children, or other relatives permanently living at the same address as the employee), or the employee together with all members of his or her immediate family meet any of the criteria stated in i-iii above.

In addition to these specific instances, there may be additional circumstances in which a conflict is found to exist. Any College Representative who feels that he or she may have a conflict, now or in the future, should report all pertinent details to his or her supervisor or the College’s Compliance Officer. The supervisor will be responsible for referring the question to the appropriate Vice President or the Compliance Officer

Each faculty member participating in a sponsored project must disclose whether or not he or she has external affiliations that may constitute a conflict by falling within the criteria stated in paragraphs i-iv above. Specific requirements for the disclosure and review of conflicts of interest are in the Canisius College Conflict of Interest Policy for Sponsored Research Projects.

c. Sponsored Research. In the area of research funded by commercial sponsors or federal agencies, conflicts of interest are situations in which faculty members may have the opportunity to influence the College's business decisions in ways that could lead to personal gain or give improper advantage to members of their families or to associates. Specific requirements for the disclosure and review of conflicts of interest are in the Canisius College Conflict of Interest Policy for Sponsored Research.

Projects available here.

d. Board of Trustees and Senior Administration Disclosures.  The members of the College’s Board of Trustees are also subject to conflict of interest scrutiny because of the potential for conflicts when a trustee is doing business with the College. Each year, the Secretary of the Board of Trustees shall circulate a Conflict of Interest disclosure form to each trustee and senior administrator of the college in which they will be asked to disclose any conflicts, within the meaning of section 5.a.i-iv above or any other facts or circumstances that could create a conflict. The disclosure forms will be reviewed by the Board’s Committee on Trusteeship and the existence of any conflicts will be reported to the Executive Committee of the Board for appropriate action. It is recognized that corporations or entities owned or controlled by members of the Board may be doing business with the College. It is incumbent upon the Board to design appropriate procedures to insure that all such dealings are subject to review by independent directors (and, where appropriate, legal counsel) and are determined to be fair and equitable.

• Honor all non-disclosure agreements entered into by or on behalf of the College;
• Abide by all laws, regulations, contracts and policies of the College governing the use of copyrighted materials, patented ideas, trademarks, licenses, and proprietary information;
• Refrain from any activity that constitutes infringement of intellectual property of the College or any other person; and
• Properly attribute the work and ideas of others

a. Contractors and Others.  College Personnel shall not give, offer or promise anything of value to any prime contractor, subcontractor or others for the purpose of improperly obtaining or receiving favorable treatment. However, it is an acceptable practice for College Personnel to provide meals, refreshments, entertainment, and other business courtesies of reasonable value to non-governmental persons in support of legitimate College activities, provided that:

• The business courtesies are not provided for the purpose of improperly obtaining or receiving favorable treatment, are infrequent in nature, are not lavish or extravagant and have been approved by the respective Vice President; and
• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization (It is the offeror’s responsibility to inquire about any prohibitions or limitations of the recipient’s organization before offering any business courtesies).

b. Government Officials.  College Personnel shall not give, offer or promise anything of value to any government official to enhance relations with that official or the government, regardless of whether that official is in a position to influence any government decision with respect to Canisius or its activities. For purposes of the preceding sentence, government contractors and subcontractors are considered to be government officials. Things of value include, but are not limited to, entertainment, meals, refreshments, gratuities or gifts. Although some agencies may permit government employees to accept items of nominal value on an infrequent basis, College Personnel shall not give, offer or promise anything of value to any government official without the written approval of their respective Vice President stating that taking such action is acceptable under the applicable agency's rules and policies.

c. Acceptance of Business Gifts; “Kickbacks”.

i. In General.  It is the policy of Canisius College to treat all vendors, suppliers and business associates with respect and fairness and to avoid even the appearance of providing favored treatment. We must be particularly sensitive to situations where accepting business courtesies such as meals, gifts or entertainment might create the appearance of favoritism toward a vendor, supplier or business associate. This section sets forth some general guidelines for determining whether a business courtesy is appropriate. Individual departments of the college may adopt policies that are more restrictive than these Standards.

ii. Acceptance of Meals and Entertainment from Vendors.  College Personnel may accept meals, refreshments and modest entertainment (not to exceed $75 in value) from employees of vendors, suppliers or business associates when such are reasonable in frequency, and when such acceptance would not affect the reputation of the College for honest and fair dealings. Common sense is the best gauge for defining the term "reasonable." If something seems reasonable to most people, then it is most likely an appropriate activity.

iii.  Acceptance of Meals and Entertainment from College Personnel.  Meals, refreshments, gifts and modest entertainment accepted by College Personnel from their supervisors or accepted by supervisors from their associates should also be reasonable in frequency and value and should be consistent with the College’s policies regarding appropriate reimbursements for business-related activities.

iv. Kickbacks and Bribes.  College Personnel should never accept anything -even an item of minimal value -if the item is offered with the expectation or even the appearance that the person giving the gift will receive favorable treatment in return. This applies to items offered by outside customers or suppliers and is especially important in the bidding process where even a minor gift may be interpreted as earning an advantage. The College specifically prohibits soliciting any form of bribe or kickback. These are criminal acts, which carry severe penalties both for the College and all employees involved. Given the seriousness of these matters, all College Personnel should report immediately to their supervisors if they are offered money, services or gifts (other than advertising and promotional items or of the kind identified in section 10.c.ii) by a supplier or prospective supplier of the college.

v. Loans.  Except for loans from banks and financial institutions generally available at market rates and terms, College Personnel or members of their families may not accept any loan, guarantee of a loan or payment from an individual or firm doing or seeking to do business with the College.

vi. Accommodations and Travel.  It is not permissible to accept any accommodation or travel of any value whatsoever, unless rendered in conjunction with the performance of College business.

a. Acceptable Use
Canisius College computer and network systems are intended for use in College-related research, instruction, learning, enrichment, and administrative activities. Internet access and all Canisius electronic communication systems, such as e-mail and voice mail, are made available to College Personnel only to carry out their activities on behalf of the College. The College expects faculty, staff, and students to use electronic resources in a lawful and responsible manner consistent with the College’s mission of education, research, and service. Any personal use of these services by College employees shall not interfere with their official responsibilities and shall not violate any College practice or policy.

Users are expected to adhere to reasonable and necessary security habits when using College resources. These habits include:

• Keeping account information, including passwords, confidential;.
• Logging out of computers or using a password-protected screensaver when leaving the office;
• Running College-provided antivirus and antispyware software;
• Installing operating system updates when prompted;
• Using caution when opening email attachments and other unexpected data;
• Adhering to the standards of outside resources accessed from the Canisius network;

b. Privacy and Personal Use
Since the College’s communication systems are the property of the College, all communications are subject to review by appropriate and authorized College Personnel at any time. Data may be retained in backup systems, even after its apparent deletion.

College Personnel should be aware that personal privacy in their use of the College’s communication systems or information sent to or from, or stored in, the College’s communication systems cannot be guaranteed in the event of legal or disciplinary proceedings.

If it appears that the integrity, security, or functionality of the College’s network and computer resources are at risk, Canisius College reserves the right to take any necessary action to investigate and remediate the problem. This action may include monitoring network activity or viewing user-generated files. In such cases, a written report of the findings will be forwarded to the appropriate College officials.

In order to assure continuity for academic and administrative departments, similar procedures may be used after an employee is separated from the College or no longer able to perform required duties.

Employees are responsible for exercising good judgment regarding the personal use of College computing resources. If there is any uncertainty regarding personal use of network or Internet resources, employees should consult with their supervisor or manager. At no time should a College resource be used in a way that is at odds with the employee handbooks published by the Human Resources department.

c. Unacceptable Use
Under no circumstances shall an employee of Canisius College:

• Engage in any illegal activity using College equipment;
• Engage in any activity contrary to College policy using College equipment.
• Introduce malicious software into the campus computer network;
• Reveal account information or allow the use of College computer resources by people outside of the Canisius community;
• Attempt to breach, disrupt, eavesdrop on, or otherwise tamper with network communication;
• Access a system or resource using another user’s account information;
• Use College equipment or network resources to violate intellectual property laws;
• Use Canisius equipment or network resources for personal commercial or for-profit activities; or
• Use Canisius equipment or network resources for viewing or exchanging pornography.

a. Employment Decisions.  College Personnel shall abide by the policy that covers their position at the College. Those policies include:

• For Faculty: Part II.A: Norms of Faculty Status and Welfare (Faculty Handbook)
• For Administrators: Part II.B: Personnel Policies for Administrators (Administrators’ Handbook)
• For Librarians: Part II.D Personnel Policies for Librarians (Librarian Handbook)
• For Clerical and Technical Staff: PartII.C: Personnel Policies for Clerical and Technical Staff (Clerical and Technical Staff Handbook)
• For Adjunct Faculty: Adjunct Faculty Handbook

b. Harassment Prohibited.  College Personnel shall abide by the “Canisius College Harassment Policy,” located here.

c. Athletics.  College Personnel involved in intercollegiate athletics shall comply with the Department of Athletics Compliance Manual located here.

• Any program must be free and open to the public.
• The program must include a formal presentation on the part of the political candidate and offer an opportunity for questions and answers from a panel and/or the audience.
• The program must not serve as a fundraiser for the candidate or his/her political party.
• The college reserves the right to require payment in advance from a political candidate or his/her party for costs associated with the program. This may include, but is not limited to: maintenance costs, security, utilities, audio/visual and staff time.
• The program must not place an undue burden on the college’s staff, facilities or other resources.
• Political candidates/parties must recognize that the college is in no way endorsing the views expressed by the speaker(s), and allows such a program only in the interest of the advancement of education.
• The college reserves the right to cancel any program or activity on campus, at any time, which poses a clear and present danger to the college or local community.
• Persons wishing to approach the college with requests involving political candidates should contact the college’s associate vice president for public relations who will serve as coordinator for such a program.