Conflict of Interest Policy

Lehigh is committed to conducting its fiduciary responsibilities with the utmost level of integrity. In pursuant of our core mission and values, and compliance with federal and state laws, the university has created the Conflict of Interest Policy (PDF) to identify potential instances that may interfere with an employee’s unencumbered judgement.

The following will provide guidance on:

  • The University’s definition of “Conflict of Interest”;
  • To whom the policy applies;
  •  Required disclosures;

Email your questions to inaudit@lehigh.edu

What is a Conflict of Interest?

The university defines a Conflict of Interest (COI), including an apparent conflict as any employee who:

“Has a significant relationship, whether economic or otherwise as owner, investor, officer, director, trustee, partner, employee, consultant, or recipient of a gift (whether in money, goods or services, of a value greater than $100 whether received directly or indirectly) with any entity (person, firm, corporation, or organization) that supplies or receives funds, goods, services, or required approvals to or from the University, or proposes to do so in the near future.”

This definition extends to any employee who:

“Has a relationship (including but not limited to full or part time employment, serving in a consulting or advisory capacity whether compensated or not, or having an ownership interest) with any other entity engaged in the delivery of educational or other services that fall within the scope of the University’s activities or which may influence the exercise of their professional judgement on behalf of the University.

To whom does the policy apply?

Trustees and Officers

State and Federal regulation maintain that all material information between the University and a Trustee, Officer, their immediate families (spouse, child, brother, sister, parent, grandparent, grandchild, domestic partner, and the respective spouses of the foregoing or any person residing within one’s household), or an entity in which they have a significant relationship is properly disclosed to the Director of Internal Audit and the respective Dean or Vice President

Faculty and Staff

In the event that faculty and staff face a real or apparent conflict of interest, it is the employee’s responsibility to disclose all pertinent information to the Director of Internal Audit and the respective Dean or Vice President.

How is a Conflict of Interest Disclosed?

The university conducts annual reviews of COI with all trustees, officers, faculty, and staff. Each employee must review the updated Conflict of Interest policy, and ensure that they are in agreement with its terms.

If the individual has, are currently, or will have, to the best of their knowledge, any potential or real conflicts of interest; The Corporate Secretary and Director of Internal Audit will review the responses and attempt to resolve any significant conflicts with the individual. If the issues cannot be resolved, it is then take to the next level of supervision.

If at any time a COI arises after the policy has been reviewed, the individual must notify the Corporate Secretary or Director of Internal Audit in writing.