Policy Reference No: B21
Date of Last Update: 10/2/2026
Responsible Division: Office of the President/Administration
Purpose
The purpose of this policy is to ensure that Tompkins Cortland Community College operates in compliance with applicable New York State laws and SUNY policies governing conflicts of interest. The fundamental principle guiding its implementation is that no employee should have, or appear to have, any personal or financial interests, relationships, or affiliations that conflict with the interests of the College. The policy is intended to educate employees about situations that generate potential conflicts of interest, and provide procedures for disclosing and addressing actual, potential, or apparent conflicts of interest.
References
- New York Public Officers Law §§ 73, 73-a, and 74
- New York Education Law Article 126 § 6306
- New York General Municipal Law Article 18 §803
- Guidance of the New York State Commission on Ethics and Lobbying in Government
- G3 – Nepotism Policy
- Applicable collective bargaining agreements
Contacts
John Geer, Vice President of Administration, , ext. 4440, jg128@tompkinscortland.edu
Nancy Murphy, Assistant to the President, , ext. 4367, ncm011@topmkinscortland.edu
Policy Statement
This Policy applies to all employees of the College, including College officers, employees involved in procurement, contracting, hiring, supervision, purchasing, grants administration, research administration, vendor management, and financial decision-making, and volunteers acting on behalf of the College.
Conflict of Interest: A conflict of interest exists when an employee’s duty or responsibility to the College may be compromised, or may appear to be compromised, by personal, financial, professional, familial, romantic, business, or other outside interests, commitments, obligations, or relationships. A potential conflict of interest exists when circumstances may lead to the divergence between private and College interests. An apparent conflict of interest exists when an independent observer might question whether the employee’s actions can reasonably be influenced by considerations of personal gain, financial or otherwise.
Related Person: An employee’s spouse, domestic partner, parent, natural or adopted child, grandparent, grandchild, great-grandchild, sibling, or the spouse or domestic partner of the employee’s child, grandchild, great-grandchild, or sibling.
Financial Interest: An employee has a “financial interest” if, either directly or indirectly, through a relationship involving business, investment, or related person, he/she has:
- An ownership or investment interest in any entity with which the College has a transaction or affiliation;
- A compensation arrangement with any entity with which the College has a transaction or affiliation;
- A potential ownership or investment interest in, or compensation arrangement with any individual or entity with which the College is considering or negotiating a transaction or arrangement.
NB (nota bene/Take Notice): The definitions contained in this Policy are intended to implement and supplement applicable requirements of New York Public Officers Law §§ 73, 73-a, and 74; General Municipal Law Article 18; New York Education Law Article 126; and applicable SUNY policies. Where a term is specifically defined by statute, that statutory definition shall control.
Examples of Conflicts of Interest
Conflicts of interest may arise in many forms. Examples include, but are not limited to:
- Participating in the hiring, promotion, evaluation, supervision, discipline, or termination of a person with whom there exists a familial, romantic, personal, or business relationship;
- Romantic involvement with a person where a reporting, evaluative, or supervisory relationship exists;
- Influencing decisions related to College purchases, contracts, or procurement activities that may result in personal or financial gain;
- Accepting, soliciting, or offering bribes, kickbacks, gifts, gratuities, or other items of value intended to influence official actions;
- Inappropriate use of College funds, assets, personnel, resources, equipment, or confidential information for personal or professional gain;
- Engaging in outside employment, consulting, or business activities that interfere with College responsibilities or create divided loyalties;
- Participating in activities where an outside individual, organization, or entity benefits improperly at the expense of the College; or
- Any activity that may result in improper personal benefit, advancement, favoritism, or the appearance of impropriety.
This list is illustrative and not exhaustive. All College personnel are expected to exercise sound judgment and seek guidance whenever uncertainty exists regarding potential conflicts.
Disclosure Requirements
Duty to Disclose: Employees have a duty to disclose on an ongoing basis any current, proposed, or pending situations that may constitute a conflict of interest and should disclose the material facts relating to any conflict of interest to their supervisor as soon as the existence of a possible conflict of interest is known. Any employee or supervisor who has questions about this policy or its application may seek guidance from the Office of Human Resources.
Annual Disclosures: The College may require conflict of interest disclosure forms and annual certifications from Management/Confidential employees.
Disclosure of Interests in College Agreements: Pursuant to New York General Municipal Law Article 18 §803, employees must promptly disclose in writing any direct or indirect financial interest in an actual or proposed College contract, purchase agreement, lease agreement or other agreement, including oral agreements. The disclosure must be made to the employee’s supervisor and the division Vice President, who will consult with the President. The President will inform the College’s governing body and notifications will be included in the official record of the governing body.
Reviewing and Managing Conflicts of Interest
Once a conflict of interest is disclosed, the relevant College administrator will determine the next steps with respect to the conflict of interest. The College may determine that the conflict of interest should be reduced, eliminated, or managed, with a management plan. Any management plan will depend upon the facts and circumstances of the specific matter.
Enforcement
Violations of this Policy are subject to disciplinary action, including but not limited to written warnings, removal from decision-making authority, or termination.
Reporting Concerns
Employees are encouraged and expected to report known or suspected violations of this Policy to the College President or Vice President, Administration.
Non-Retaliation
No employee shall be subjected to retaliation for reporting a concern in good faith; seeking ethics advice; participating in an investigation; or cooperating with a compliance review.
Training
The College may require mandatory ethics, conflict-of-interest and relevant training for its employees.
Relationship to Collective Bargaining Agreements
Nothing in this Policy shall be construed to diminish any rights afforded to employees under applicable collective bargaining agreements. To the extent a provision of this Policy conflicts with a collectively bargained provision governing terms and conditions of employment, the collective bargaining agreement shall govern unless a contrary result is required by federal or state law.
Resolution Number
2026-2027-6