Conflict of Interest

Last Updated: 10/22/2025

1. Purpose

This statement sets forth Iona University's policy on conflict of interest and related issues pertaining to employees. The purpose of this policy is to ensure that all institutional decisions are made solely to promote the best interests of Iona University without favor or preference based on personal considerations, and to provide for the highest ethical conduct with respect to the actions and business relationships of all employees.

2. Scope

All employees shall exercise the utmost good faith in all matters relating to their duties and responsibilities to Iona and in discharging their duties and responsibilities to Iona shall at all times act in the best interests of Iona University. Employees shall not use their positions, or confidential information gained therefrom, to their personal advantage. Furthermore, the judgment and independence of employees may not be impaired or appear to be impaired in the discharge of their duties and responsibilities on behalf of Iona University because of any activity in which they may engage or any personal or financial interest or relationship they may have. For purposes of this policy, a "conflict of interest" is defined to be any activity that violates, or could potentially violate, the foregoing standard.

Each employee is responsible for recognizing the possibility of a conflict of interest and for disclosing it pursuant to the procedures described below.

COMPLIANCE/QUESTIONNAIRE: It is the responsibility of all employees to familiarize themselves with this policy and to comply with and ensure compliance with related parties with this policy. All full-time faculty, administrators, and staff are mandated to complete the Conflict-of-Interest Disclosure form at the time of hire and on an annual basis, with updates when needed. Full disclosure is necessary to accurately assess and manage all conflicts of interest and/or the appearance of any conflict of interest. 

3. Policy 

It is not possible to describe every instance in which a conflict of interest might arise. Without limiting the general standards set forth above, the following are specific instances of activities that may create a conflict of interest:

1. Financial Interests: Direct or indirect financial or other interests in (including interests or relationships of Related Parties, including spouse, parents, descendants, parents' descendants and spouse's parents' descendants) with any business or entity which has a business, financial or other relationship with, or is a competitor of, Iona University.
   An actual or potential conflict of interest occurs when employees or their family members have a material financial interest or personal interest in the transaction or in an entity that proposes to do business or does business with the University. 
   In this situation, the employee must make full disclosure of all material facts concerning such interest to the Office of General Counsel as soon as he or she becomes aware of a potential transaction involving the University. 
2. Other Employment/Service in Other Entities: Service as a director, trustee, officer, partner, member of a scientific advisory board, employee, manager or consultant, or other activity taken on behalf of a business or entity which has a business or financial relationship with, or is a competitor of, Iona University. Outside employment in a job, consulting work, or entrepreneurial venture outside of Iona.
3. Acceptance of Gifts, Etc.:  Solicitation or acceptance by employees or related parties of personal gifts, gratuities, payments or consideration of any kind, loans (other than from established banking or financial institutions), or other favors from any person or organization arising because such person or organization does, or is seeking to do, business with, establish a relationship with Iona University, except (i) de minimis gifts whose aggregate value does not exceed $100.00 per annum, (ii) reasonable business meals and entertainment provided in the regular course of business and (iii) other business travel and entertainment which has been disclosed and approved pursuant to this policy.
   Exceptions to the Gift Policy may be authorized by the President, Provost, and General Counsel. Any exception to the gift policy must be approved in writing with a copy of the approval sent to the Office of General Counsel.
4. Use of Confidential Information: Disclosure or other use of confidential or privileged information gained because of such person's relationship with Iona University for direct or indirect personal advantage.
5. Employment of Relatives: There are occasions where the University employs individuals related by blood, marriage or otherwise. Whenever this occurs, or is about to occur, the employee should bring this fact to the attention of the University as soon as possible. In circumstances where family members are employed at the University, they should follow certain common-sense rules to avoid a conflict of interest, or a difficult work environment. One family member should never supervise another or take any part in matters relating to the hiring, promotion, compensation or retention or employment of another family member.
6. Board of Trustees: Employees must also avoid situations that may create an actual, potential, or apparent conflict of interest between an employee and a member of the Board of Trustees. This includes business relationships, loans, gifts, or other financial transactions involving a trustee and an employee or a member of the employee’s family. Whenever this type of situation arises, or is about to arise, the employee must bring it to the attention of his or her supervisor and the General Counsel.

4. PROCESS FOR DISCLOSURE; RESOLUTION OF CONFLICTS

Full-time employees must disclose all such interests and relationships as outlined in this policy. In the event an employee has a conflict of interest or must otherwise make a disclosure as required by the preceding paragraph, such employee shall disclose it immediately in writing to the Office of the General Counsel. If it is determined that a conflict of interest exists, the conflict of interest will be addressed as follows:

1. Unless otherwise authorized, the individual with the conflict of interest may take no part in Iona University decisions to which the conflict relates.
2. In addition, the activity giving rise to the conflict of interest may be prohibited.
3. The President shall have the final decision in addressing any conflict of interest.

INFRACTIONS

This policy will be strictly enforced. Employees who violate this policy will be subject to disciplinary action including possible dismissal.
Questions as to the applicability and interpretation of this policy should be directed to the Office of the General Counsel for Iona University.

Approval and Revision History

• Approved by: Office of the General Counsel
• Effective Date: 10/22/2025
• Last Review Date: 04/01/2017, 10/01/2002, 09/01/1996