All employees need to be aware of the statutory requirements regarding Conflicts of Interest, and must certify their understanding of these policies within thirty (30) days of hire and every two years thereafter.

Conflict of Interest Law

In general terms, a conflict of interest exists when any employee in a position to make or influence a decision on behalf of the University and stands to personally benefit from that decision (this also extends to any individuals in the employee’s household, persons to whom the employee is related by blood, adoption, or marriage within the third degree of consanguinity, or persons with whom the employee has substantial and continuing outside business relationship).

Any University employee receiving pay or other tangible benefits from an outside source for duties that are in any way related to their University position is engaged in a conflict of interest. Additionally, the use of University time or resources for non-official business could be construed as theft.

Employees are to disclose any conflict of interest in a written statement to their supervisor before the activity takes place.

For a complete text of the Code of Ethical Standards, please refer to: Massachusetts General Laws, Chapter 268A.


Re-certification

The Massachusetts State Ethics Commission Conflict of Interest Certification is now provided in an online program which should take under an hour to complete. Accessibility instructions are included.

At the end of the assessment, a Certificate of Completion will appear on your computer screen. Please print and save two copies of this certificate; keep one copy for your records, and send the other copy to Human Resources & Equal Opportunity and Outreach for placement in your personnel file.

An employee is not prohibited from accepting reimbursement, waiver, or payment of travel expenses, if a prior written determination is made that 

  1. such acceptance will serve a legitimate public purpose and 
  2. such public purpose outweighs any special non-work-related benefit to the employee, or to the person providing payment of expenses. 

This would require completion of the Appointed employee reimbursement of travel expenses disclosure form pursuant to 930 CMR 5.08(2). 

For employees presenting at the conference, the determination should first be made if the presentations constitute a legitimate speaking engagement under 930 CMR 5.08 (4)(a). It is important to note that the only expenses that are able to be covered under 5.08(4)(a) may cover only the day or days on which the public employee is actually speaking and the days on which the public employee must travel to the conference and return to the Commonwealth. 

A public employee who speaks only on the first day of a week-long conference can accept travel expenses in connection with the other days only subject to compliance with 930 CMR 5.08(2). This would require completion of the Appointed employee reimbursement of travel expenses disclosure form pursuant to 930 CMR 5.08(2). The form should be completed by the employee’s appointing authority (head of their department). 

The employee is responsible for retaining the approved form. Please attach the approved form to the appropriate Travel Request in Concur.