Article II.03 Conflict of Interest Policy

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 certain employees and members of the Board of Trustees.

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

Conflicts of Interest
All elected and appointed members of the Board of Trustees as well as certain employees of St. Charles Community 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.

Any member of the St. Charles Community College Board of Trustees of who has a “substantial personal or private interest” in any measure, bill, order, ordinance, or other action proposed or pending before the Board of Trustees must disclose that interest to the Recording Secretary, and the disclosure will be recorded in the official meeting minutes. Substantial personal or private interest is defined as ownership by the individual, his/her spouse, his/her 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.

Disclosure Reports
Each member of the St. Charles Community College Board of Trustees, candidate for the St. Charles Community College Board of Trustees, the Vice President for Administrative Services, and the Director of Purchasing will disclose the following information by May 1, or the appropriate deadline as referenced in Section 105.487 of the Missouri Revised Statutes, if any such transactions occurred during the previous calendar year:

  • For such person and all persons within the first degree of consanguinity or affinity of such person, the date and the identities of the parties to each transaction with a total value in excess of five hundred dollars, if any, that such person had with St. Charles Community College other than compensation received as an employee or payment of any tuition, fees or penalty due to St. Charles Community College, and other than transfers for no consideration to St. Charles Community College.
  • The date and identities of the parties to each transaction known to the person with a total value in excess of five hundred dollars, if any, that any business entity in which such person had a substantial interest, had with the St. Charles Community College, other than payment of any tuition, fees, or penalty due to St. Charles Community College; and other than transfers for no consideration to St. Charles Community College.
  • The Vice President for Administrative Services and the Director of Purchasing will disclose by May 1, or the appropriate deadline as referenced in Section 105.487, RSMo, the following information for the previous year:
    • The name and address of each of the employers of such person from whom income of one thousand dollars or more was received during the year covered by the statement;
    • The name and address of each sole proprietorship that he/she owned; the name, address, and 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 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 or more of any class or outstanding stock, limited partnership units, or other equity interests;
    • The name and address of each corporation for which such person served in the capacity of a director, officer, or receiver.

Filing of Reports
The financial interest statements will be filed at the following times, but no person is required to file more than one financial interest statement in any calendar year:

  • Every person required to file a financial interest statement will file the statement annually, not later than May 1, and the statement will 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 statement to report additional interests acquired after December 31 of the covered year until the date of filing of the financial interest statement.
  • Each person appointed to the Board of Trustees or employed as Vice President for Administrative Services or Director of Purchasing will file the statement within thirty days of such appointment or employment covering the calendar year ending the previous December 31.
  • Every candidate required to file a personal financial disclosure statement will file no later than fourteen days after the close of filing at which the candidate seeks election. The time period of this statement will cover the twelve months prior to the closing date of filing for candidacy.

Financial disclosure reports giving the financial information required will be filed in the office of the College President and with the Missouri Ethics Commission. The statements will be available for public inspection and copying during normal business hours.

Filing of Policy
A certified copy of this policy, adopted prior to September 15th, will be sent to the Missouri Ethics Commission within ten days of its adoption.

Effective Date
This policy will be in full force and effect from and after the date of its passage and approval and shall remain in effect for two years from the date of passage.

Content Owner: Julie Parcel - jparcel@stchas.edu
Revision Dates: Adopted by Board of Trustees August 20, 2018

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