Compliance Document

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Core Requirement - 3.2.3  The board has a policy addressing conflict of interest for its members.

Judgment of Compliance:  Compliance

Narrative/Justification for Judgment of Compliance:

Tennessee Board of Regents (TBR) Policy 1:02:03:10, “Conflict of Interest” [1], defines “general principles which should guide the actions of members of the Board and of employees,” and includes “illustrations of activities which potentially constitute a conflict of interest.” Specific concern is expressed in Section 3 for two types of conflict:

“A ‘conflict of interest’ occurs when the personal interests, financial or otherwise, of a person who owes a duty to the Tennessee Board of Regents and its constituent institutions (Regents and all employees) actually or potentially diverge with the person’s professional obligations to and the best interests of the TBR and its Institutions.

“A ‘conflict of commitment’ occurs when the personal or other non-work related activities of an employee of the TBR and its constituent Institutions impair the ability of that employee to meet their commitments of time and energy to the TBR and its Institutions.”

To enforce policies and laws, TBR requires all members of the Board and many key institutional leaders to submit disclosure forms. The TBR Disclosure Review Committee evaluates written disclosures. All possible conflicts of interest related to family members, business affiliations, gifts, educational benefits, use of staff, intellectual property, real property, purchases, or other concerns are subject to review and sanction.

Members of the Board of Regents, the Chancellor of the system, members of the senior staff of the system office, all institutional presidents, and other key institutional personnel are required to file a financial disclosure form within one month of their initial appointment and annually thereafter in January.

At the institutional level, TBR Conflict of Interest Disclosure Forms are completed by deans, administrative department heads, professional level employees of the athletic department, and employees who report directly to the President. These forms are on file in the President’s Office. [2]

Documentation Location*
[1] TBR Policy 1:02:03:10, Conflict of Interest http://www.tbr.state.tn.us/policies_guidelines/
governance_policies/1-02-03-10.htm
[2] Southwest Conflict of Interest Disclosure Forms http://sacs.southwest.tn.edu/ref-docs/3.2.3-Doc2-Conflict-of-Interest-Form.pdf
*Hard copies are available in the SACS Project Document Room at the College.

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