105 Code of Ethics/Conflicts of Interest

P-105.1 Code of Ethics – St. Charles Community College adheres to the standards of professional ethics as prescribed by the State of Missouri and establishes the following policy and procedure to disclose potential conflicts of interest and substantial interests for employees of the College and members of the Board of Trustees.

Declaration of Policy - The proper operation of the College requires that the employees and members of the Board of Trustees be independent, impartial, and responsible to the members of the College community; that decisions and policies be made through the proper channels of the College structure; that employment with the College or membership on the Board of Trustees not be used for personal gain; and that the College community and general public have confidence in the integrity of the College. In recognition of these goals, there is hereby established a procedure for disclosure by Board members, Board candidates, and certain College employees of private financial or other interests in matters affecting the College.

P-105.2 Conflicts of Interest – It is the intention of the College to avoid any real or apparent conflicts of interest. All College employees and members of the Board of Trustees serve a public-interest role and have a clear obligation to conduct all affairs of the institution in a manner consistent with this concept. All decisions affecting the College are to be made solely on the basis of the desire to promote the best interests of the College and the public good. In accordance with this expectation, all College employees and members of the Board of Trustees are expected to avoid improper outside influences on their work-related decisions or activities.

  1. All College officials, members of the Board of Trustees, and employees of the College must comply with section 105.454 of the Missouri Revised Statutes on conflicts of interest as well as any other state law governing official conduct.
  2. The laws of the State of Missouri pertaining to nepotism will be adhered to. The Board of Trustees shall not employ one of its members, nor shall it employ any person who is related to any Board member, either by consanguinity or affinity, where the vote of the Board member is necessary to the hiring of the person. Board members shall not debate or vote upon the issue of hiring any person to whom they are related.
  3. No member of the Board of Trustees shall directly or indirectly receive any compensation or remuneration, nor derive any profit or gain, by reason of his/her services. Members of the Board of Trustees will conduct themselves in a manner which complies not only with the letter of conflict of interest laws, but also in the spirit of those provisions. Board members will, at all times, make good faith efforts to avoid the appearance of a conflict of interest. If a situation arises which involves the potential for a conflict of interest, the individual Board member will declare his/her interest and will refrain from debating or voting upon the question of engaging or using the business entity in question.
  4. Any College official, member of the Board of Trustees, or employee of the College who has a "substantive or private interest" in any measure, bill, order or ordinance proposed or pending before the Board of Trustees must disclose the interest to the President of the Board of Trustees or the Vice President for Human Resources and such disclosure shall be recorded with the Board of Trustees. Substantive or private interest is defined as ownership by the individual, the individual's spouse or dependent children, whether singularly or collectively, directly or indirectly of:

    1. 10% or more of any business entity; or
    2. An interest having a value of $10,000 or more; or
    3. The receipt of a salary, gratuity, or other compensation or remuneration of $5,000 or more per year from any individual, partnership, organization, or association within any calendar year.

  5. College employees or members of the Board of Trustees shall not transact business or approve the transaction of business on behalf of the College with any person or entity, including but not limited to any company, corporation, partnership, proprietorship or organization, or any principal, officer, agent, employee or representative of such entity, with whom or which the College employee or member of the Board of Trustees has a personal, professional, business, financial, or family interest or relationship.

  6. College employees and members of the Board of Trustees shall not benefit personally from any purchase of goods or services by the College, derive personal gain from actions taken as a representative of the College, nor shall College employees or members of the Board of Trustees accept any gift, gratuity or reward in value of twenty-five dollars ($25.00) or more from any person or other entity which transacts business with the College or which seeks to transact such business.
P-105.3 Conflicts of Interest Disclosure Reports – Each trustee, trustee candidate, the College president, and the chief purchasing officer shall disclose the following information by May 1 or the appropriate deadline as referenced in Section 105.487, RSMo if any such transactions occurred during the previous calendar year: 

  1. All College employees or members of the Board of Trustees, and all such persons within the first degree of consanguinity or affinity of College employees or members of the Board of Trustees, who are involved with transactions on behalf of the College, the date and the identities of the parties to each transaction with a total value in excess of $500 (five hundred dollars), other than compensation received as an employee or payment of any tax, fee or penalty due to the College, and other than transfer for no consideration to the College.
  2. The date and identities of the parties to each transaction known to the person with a total in excess of $500 (five hundred dollars), or any, that any business entity in which such person had a substantial interest, had with the College, other than payment of any tax, fee, or penalty due to the College, and other than transfers for no consideration to the College.

The College president and chief purchasing officer shall disclose by May 1, or the appropriate deadline as referenced in Section 105.487, RSMo, the following information for the previous year:

  1. The name and address of each of the employers of such person from whom income of $1,000 (one thousand dollars) or more was received during the year covered by the statement;
  2. The name and address of each sole proprietorship he/she owned, the name, address, and the general nature of the business conducted of each general partnership and joint venture in which he/she was a partner or participant; the name and address of each partner or co-participant for each partnership or joint venture with the Secretary of State; the name, address, and general nature of business conducted of any closely held Corporation or limited partnership in which the person owned ten percent (10%) or more of any class of the outstanding stock or limited partnership units; and the name of any publicly traded corporation or limited partnership that is listed on a regulated stock exchange or automated quotation system in which the person owned two percent (2%) or more of any class of outstanding stock, limited partnership units, or other equity interests;
  3. The name and address of each corporation for which such person served in the capacity of a director, officer, or receiver.
P-105.4 Individual Filing of Reports – The financial interest (disclosure) statements shall be filed at the following times, but no person is required to file more than one financial interest (disclosure) statement in any calendar year.

  1. Every person required to file a financial interest (disclosure) statement shall file the statement annually, not later than May 1, and the statement shall cover the calendar year ending the immediately preceding December 31; providing that any employee or member of the Board of Trustees may supplement the financial interest (disclosure) statement to report additional interests acquired after December 31 of the covered year until the date of filing of the financial interest (disclosure) statement.
  2. Each person appointed to the Board of Trustees or employed as College President or Director of Purchasing  shall file the statement within thirty (30) days of such appointment or employment covering the calendar year ending the previous December 31.
  3. Every candidate required to file a personal financial disclosure statement shall file no later than fourteen (14) days after the close of filing at which the candidate seeks nomination or election or nomination by caucus. The time period of this statement shall cover the twelve months prior to the closing date of filing for candidacy. 

    Financial disclosure reports giving the financial information required shall be filed with the College and with the Missouri Ethics Commission. The statements shall be available for public inspection and copying during normal business hours.
P-105.5 Filing of Policy – A certified copy of this policy shall be sent to the Missouri Ethics Commission within ten days of its adoption.
P-105.6 Annual Certification– The College president, chief purchasing officer, each Board of Trustees member, and candidate for Board of Trustees position shall certify annually, in writing, that he/she has received, read, and understands the provisions of this policy including the potential disciplinary action for violation of this policy.

Disciplinary Action – Any College employee who violates this policy will be subject to disciplinary action up to and including termination of employment. An employee who is subject to disciplinary action based on an allegation of violation of this policy shall be entitled to full due process rights provided under the grievance process.

Members of the Board of Trustees who violate this policy will be subject to disciplinary action as provided for in the rules governing Board members. Members of the Board of Trustees are also entitled to full due process rights as provided for in the rules governing Board members.

Pr-105.1 Reporting Violations– Any employee or student having knowledge or good faith suspicion of a violation of this policy may make a report.

A report may be made to any Administrative Officer:

President 636-922-8380
Vice President for Academic and Student Affairs 636-922-8356
Vice President for Administrative Services 636-922-8359
Vice President for Human Resources 636-922-8300
Vice President for Marketing & Communications 636-922-8277
Vice President for Technology and Online Learning 636-922-8607
Vice President for College Advancement 636-922-8472

A report may be made to the President or a member of the Board of Trustees in situations where there is suspected administrative involvement in the alleged impropriety.
http://www.stchas.edu/about-scc/board-of-trustees/

A report may be made to the Board of Trustees in situations where there is suspected involvement by the President of the College in the alleged impropriety.
http://www.stchas.edu/about-scc/board-of-trustees/

A report may be made to the President of the Board of Trustees in situations where there is suspected involvement by a Board member in the alleged impropriety.
http://www.stchas.edu/about-scc/board-of-trustees/

P-105.7 Effective Date – The policy shall be in full force and effect from and after the date of its passage and approval and shall remain in effect until amended or repealed by the Board of Trustees.
Policy Code Key
P Policy PR Procedure D Definition S Supplement

Content Owner: Julie Parcel – jparcel@stchas.edu
Page Updated by: Julie Parcel
Date Issued: 8/91
Date Revised: 7/96, 7/00, 4/05, 10/09, 8/14