Examples of Non-Research COI/COC & Nepotism

The following situations are examples of prohibited conflicts of interest and commitment or nepotism.

This list is not exhaustive of the types of actual and potential conflicts that may arise in the workplace.

Employees should contact their supervisor, unit head, or local HR representative if they have questions on whether their individual circumstance creates a potential conflict of interest or commitment concern or potential for nepotism.

Example: Business Ventures and Contracting

An employee has an actual or apparent conflict of interest if:

• the employee directly or indirectly leases, rents, trades, or sells real or personal property to the university.
• the employee having relevant decision-making authority (or that employee’s family member) possesses a significant financial interest in or participates in the profits of any organization that deals or seeks to deal with the university. (See policy 4.14, definition of significant financial interest for exclusions).
• the employee is involved in independent business ventures as owner, operator, or major investor, that is doing business with the university.
• the employee accepts appointment as an officer or director or serves in any management capacity in an external commercial, industrial, business, or financial organization, or profit-making enterprise that deals or seeks to deal with the university.
• the employee can require others at the university to purchase a product in which the employee (or that employee’s family member or associate) has a proprietary interest and from which the employee (or that employee’s family member or associate) will receive income or other financial gain.
• the employee, as part of an arrangement with an entity unaffiliated with Cornell, agrees to any limitations on the employee’s performance of university duties (e.g., through agreements containing exclusive provider, non-competition, or right of first refusal clauses).

Example: Personal Gain; Misuse of University Resources

An employee has an actual or apparent conflict of interest if:

• the employee makes more than incidental use of university resources (e.g., time, facility, studios, computer technology, research, technical, or support staff, supplies, directory or distribution information, funds) for non-university purposes, including for personal business.
• the employee, without permission, utilizes the name of the university or one of its colleges or programs in connection with the promotion, marketing, or sale of a product or service in such a way as to imply university sponsorship, e.g., “The Cornell Book of _______.”

Example: Soliciting or Accepting Gifts, Gratuities, Benefits, or Favors

An employee has an actual or apparent conflict of interest if:

• the employee accepts gifts, meals, entertainment, or other items of value from vendors or other third parties that do or have business with the university or hope to do business with the university where doing so is contrary to university policy.

Example: Undue Influence, Favoritism, and Bias

An employee has an actual or apparent conflict of interest if:

• the employee’s own personal interest, financial or otherwise, or those of a family member or other third party, are or could be affected by that employee’s participation in university decisions or deliberations or other opportunity for preferential treatment to be given or received, e.g., student status, including application assessment, recruitment, or admissions, funding, hiring, purchasing goods or services, or other resource allocation decision.
• the employee takes advantage of relationships that might enable the employee to influence Cornell’s interactions with outside organizations in ways that may lead to personal gain, to the taking of improper advantage by anyone, or the improper diversion of university assets from the primary missions of the university, including the time and talents of its faculty and staff members.

Example: Nepotism 

An employee has an actual or apparent conflict of interest if:

• the employee directly or indirectly supervises the employee’s family member at the university or someone with whom the employee has a personal relationship. (see policy 6.14 definition of personal relationship)
• the employee participates on the hiring committee for a position in which one of the candidates is the employee’s family member or someone with whom the employee has a personal relationship.
• the employee initiates or participates, indirectly or directly in personnel actions (e.g., hiring, performance evaluation, work assignments, compensation, or any other terms, conditions, or privileges of employment) involving a family member or someone with whom the employee has a personal relationship.

Example: Misuse of Confidential or Official University Information

An employee has an actual or apparent conflict of interest if:

• the employee were to disclose or use for personal profit or gain of unpublished information coming from university research or other confidential university sources, or assisting outside organizations by giving them access to such information except as may be authorized by university policies.

Example: Conflicting Loyalty and Fiduciary Duties

An employee has an actual or apparent conflict of interest if:

• the employee is asked to assume duties with other organizations that might seriously divert the employee’s attention from university duties or create other conflicts of loyalty.
• the employee occupies a position in an enterprise doing business in the area of the employee’s university responsibility that is related to that field (e.g., fundraising for an external organization by an employee whose primary obligations to the university involve fundraising for the university).
• the employee, as part of an arrangement with an entity unaffiliated with Cornell, agrees to any limitations on the employee’s performance of university duties (e.g., through agreements containing exclusive provider, non-competition, or right of first refusal clauses). 

Example: Conflicts of Commitment and Time

 An employee has an actual or apparent conflict of interest if:

• the employee has external commitments, whether compensated or in a volunteer capacity, that involve frequent or prolonged absence from the university on non-university business.
• the employee accepts additional employment with another unit or a university vendor without prior approval or review of potential conflicts of interest or conflicts of commitment.
• the employee engages in outside work or other activities that impair a person’s university job performance, including misuse of a hybrid work schedule to work for another organization or engaging in self-employment while in a full-time university position.