Regents Policy 1110: Policy on Conflicts of Interest in Accordance with the Political Reform Act

Approved January 21, 1977
Amended March 16, 2017

A. University Conflict of Interest Code
In accordance with the Political Reform Act of 1974, the Regents authorize the President of the University to adopt, in consultation with the General Counsel and the Chief Compliance and Audit Officer, the University’s Conflict of Interest Code (“Code”). The President of the University may determine what University positions should be included in the Code as “designated employees” who are thereby required to file a Statement of Economic Interests (Form 700). The Code shall include as “designated employees” those University officers and employees whose position entails the making or participation in the making of decisions that may foreseeably have a material effect on any financial interest. Nothing in this delegation is intended to preclude the Board of Regents from adding positions to, or removing positions from, the Code.

B. Conflicts of Interest Requirements for Individual Regents

  1. Each Regent shall complete conflict of interest training with the same frequency as required for University employees. In addition, each Regent shall submit an annual certification to the Secretary and Chief of Staff in a form approved by the General Counsel that includes, but is not limited to, the following:
    1. They have submitted any required complete and accurate Form 700;
    2. They have completed all trainings required by Board policy;
    3. They will complete any trainings required to be completed in the coming year;
    4. They have not participated in any University decision in which they had a financial conflict of interest in the previous year;
    5. They will undertake reasonable efforts to anticipate any possible financial conflict of interest, inform the Chair and General Counsel and solicit input as to whether recusal is required; and
    6. Any other subject matter requested by the Governance and Compensation Committee.
  2. A Regent shall alert the General Counsel as soon as they become aware of any possible financial conflict of interest and seek legal advice about whether they are required to disqualify themselves from any University decision.
  3. When a financial conflict of interest requires a Regent to disqualify himself or herself on an issue on the agenda of a meeting of the Board of Regents or its committees, the Regent shall:
    1. When the item is announced, publicly identify the nature of the financial conflict of interest;
    2. Recuse himself or herself from discussing, voting, or otherwise participating in the matter; and
    3. Leave the room until after the discussion, vote, and any other disposition of the matter is concluded.
  4. Notwithstanding the requirements of paragraph (3), a Regent may address the Board about any issue for which their disqualification is required during time provided for general public comment on the issue.
  5. A Regent is expected to disqualify himself or herself from participating in or influencing any University decision in which they have a material financial interest, whether or not that University decision occurs or is planned to occur at a meeting of the Board or any of its committees or subcommittees.

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