Community Christian College
Employee Conflict of Interest Policy and Procedure
RESPONSIBLE OFFICE: Finance Office
EFFECTIVE DATE: October 20, 2026
REVIEW CYCLE: Annually
1. Purpose
Community Christian College (cCc or the College) is committed to conducting its educational, administrative, financial, academic, and athletic operations with integrity, impartiality, accountability, and Christian ethical principles.
The purpose of this policy is to identify, disclose, evaluate, and appropriately manage actual, potential, and perceived conflicts of interest that could compromise—or reasonably appear to compromise—an employee's independent judgment or the interests of the College.
This policy also supports responsible stewardship of College resources, protection of students, fair employment practices, and compliance with applicable law, nonprofit governance obligations, and institutional accreditation requirements.
2. Scope
This policy applies to all cCc employees, including:
Executive officers, administrators, department heads, and supervisors.
Faculty, instructors, academic staff, and student-services personnel.
Athletic directors, regional athletic directors, coaches, trainers, and athletic support staff.
Finance, purchasing, admissions, financial aid, recruiting, human resources, and information technology personnel.
Full-time, part-time, temporary, contracted, and other employees, as applicable to their employment arrangements.
Trustees and board committee members are subject to applicable provisions of the College's separate Board of Trustees policies and governing documents. Where this policy addresses an employee who also holds a governance role, the more specific applicable governance requirements must also be followed.
3. Definition of a conflict of interest
A conflict of interest exists when an employee's personal, financial, family, business, professional, or other outside interests interfere—or could reasonably appear to interfere—with the employee's duty to act in the best interests of cCc.
A financial or personal interest does not automatically constitute a violation. The employee must disclose the relevant facts so the College can determine whether a conflict exists and what safeguards are necessary.
The following categories apply.
3.1 Actual conflict. An employee has a present competing interest that affects, or could improperly affect, a College decision or responsibility.
3.2 Potential conflict. Circumstances exist that could develop into a conflict, such as an employee participating in the selection of a vendor owned by a family member.
3.3 Perceived conflict. A reasonable, informed observer could question whether the employee's personal interests influenced a decision, even if no improper conduct occurred.
3.4 Financial interest. An employee or a related person or business has an ownership interest, investment, compensation arrangement, financial benefit, or other material economic interest that could be affected by a College decision.
3.5 Related person. For this policy, a related person includes a spouse or domestic partner, parent, child, sibling, household member, or another person with a sufficiently close personal or financial relationship to create a potential conflict. The College may also consider relationships involving extended family members where the circumstances warrant it.
4. Examples of conflicts requiring disclosure
An employee must disclose a situation when the employee knows, or reasonably should know, that a personal or outside interest may intersect with College responsibilities.
Examples include:
A. Purchasing and contracts
Recommending, selecting, or approving a vendor in which the employee or a related person has a financial interest.
Directing College business to a company owned by the employee, a family member, or a close business associate.
Participating in contract negotiations where the employee may receive a personal benefit.
B. Hiring and supervision
Recommending, hiring, evaluating, promoting, disciplining, or determining compensation for a related person.
Supervising or exercising significant authority over a person with whom the employee has a close personal or financial relationship.
Participating in a recruitment or selection decision where personal loyalties may interfere with objective evaluation.
C. Athletics and student eligibility
Making eligibility, playing-time, travel, team-selection, recruiting, scholarship, or disciplinary decisions for a related person or a person with whom the employee has a material personal or financial relationship.
Receiving personal compensation or benefits from an outside sports organization, recruiting service, vendor, or team that does business with cCc.
Directing College athletic funds, contracts, equipment purchases, travel arrangements, or coaching assignments for personal gain.
Accepting payments or benefits from a third party in exchange for influencing student participation or College athletic decisions.
D. Outside employment and business activities
Operating or working for a business that competes with cCc or seeks College contracts, where the outside activity could compromise the employee's duties.
Using College time, confidential information, facilities, equipment, personnel, or student contacts for an unauthorized private business.
Accepting outside work that materially interferes with assigned duties or creates divided loyalties.
Outside employment is not automatically prohibited. Disclosure and review are required when the outside activity could create a conflict, interfere with job performance, or misuse College resources.
E. Gifts, favors, and hospitality
Accepting cash, loans, commissions, kickbacks, personal discounts, or other benefits intended to influence a College decision.
Accepting gifts or entertainment from a vendor, contractor, recruiter, or other party seeking College business when the benefit could affect—or appear to affect—impartial judgment.
Soliciting personal benefits in connection with an employee's position.
Nominal promotional items or ordinary refreshments may be permissible if they do not influence a decision and are consistent with College procedures. Cash and cash equivalents must never be accepted in connection with a College business decision.
F. Student-related decisions and confidential information
Using confidential student, applicant, employee, donor, or financial information for personal benefit or to benefit a related person.
Providing preferential treatment in admissions, grading, financial aid, student employment, discipline, or athletics because of a personal relationship.
Using a College position to obtain an improper personal advantage.
G. Institutional leadership and compensation
Participating in decisions regarding one's own compensation, bonus, benefits, contract terms, or reimbursement outside established authorization procedures.
Approving expenses, reimbursements, purchases, or payments that personally benefit the approving employee.
Participating in a decision that could confer an improper private benefit on the employee or a related person.
5. Activities that are not automatically conflicts
The following are not automatically prohibited, although disclosure may still be necessary:
Having a second job unrelated to College duties.
Owning ordinary investments that do not create material influence over a College decision.
Having a family member who attends or works for the College, provided appropriate safeguards are in place.
Participating in a church, charitable organization, professional association, or community activity.
Receiving normal employee compensation and benefits under authorized College policies.
Purchasing goods or services from a vendor on the same terms available to the general public, where no special benefit or decision-making conflict exists.
The College will assess the actual circumstances rather than presume wrongdoing solely because a relationship or outside interest exists.
6. Employee responsibilities
Every employee must:
Act honestly and in the best interests of the College.
Disclose actual, potential, or perceived conflicts promptly and accurately.
Complete the conflict of interest disclosure form upon request and at least annually, as directed by the College.
Submit an updated disclosure when circumstances materially change.
Refrain from approving, negotiating, recommending, or influencing a transaction while a disclosed conflict is under review, unless specifically authorized to provide limited factual information.
Follow all restrictions or safeguards imposed by the College.
Protect confidential College information and records.
Cooperate with reasonable reviews and inquiries.
Disclosure does not itself authorize the activity or transaction.
7. Policy and approval procedure
Step 1 — Submit disclosure. The employee completes the Employee Conflict of Interest Disclosure and Request Form attached to this policy. The form must describe the relationship, financial interest, outside activity, proposed transaction, and the employee's role in the matter.
Step 2 — Refer the request. The form is submitted to Human Resources or the designated compliance officer. If the employee's position or the nature of the request makes that reporting channel inappropriate, the employee may report directly to the President, Board Chair, or another authorized, disinterested official.
Step 3 — Review the facts. The reviewer evaluates the nature and seriousness of the conflict, the potential benefit, the employee's decision-making authority, the impact on students and College resources, and any applicable legal, contractual, or accreditation requirements.
Step 4 — Determine appropriate safeguards. The College may approve the activity with conditions, require recusal, change reporting arrangements, require competitive bids or independent review, restrict access to information, or prohibit the transaction or activity.
Step 5 — Obtain appropriate authorization. Transactions involving executives, substantial financial interests, related-party contracts, or possible private benefit must be escalated to a disinterested decision-maker or the Board of Trustees when required by College governance procedures or applicable law. No employee may approve their own request.
Step 6 — Document the decision. The College records the decision, its rationale, any recusals, applicable conditions, and the authorized approver. The employee receives written notice of the determination.
Step 7 — Monitor compliance. The College may periodically review approved arrangements and require renewed disclosure if the facts change. Approval may be modified or withdrawn if circumstances warrant.
8. Standards for approving a transaction
A conflict-related transaction may be approved only if the authorized, disinterested reviewer determines that:
The arrangement is consistent with the College's mission and legitimate institutional interests.
The College receives a reasonable benefit and the terms are fair.
Reasonable alternatives have been considered where appropriate.
Any applicable competitive procurement, compensation, financial, and approval requirements have been satisfied.
The transaction does not result in prohibited private benefit, unlawful self-dealing, or another violation of law or College policy.
Appropriate safeguards are in place and documented.
If these conditions cannot be met, the College may prohibit the arrangement.
For compensation and related-party transactions involving persons with substantial authority over the College, the institution should follow the additional approval, comparability, and documentation procedures required by applicable laws, the IRS, and its governance documents.
9. Gifts and outside benefits
Employees must not solicit or accept benefits in exchange for influencing a College decision.
Any proposed gift, hospitality, or outside benefit that could reasonably influence an employee's judgment must be disclosed before acceptance whenever practicable. The College may require the item to be declined, returned, surrendered to the College, or otherwise handled under written instructions.
A gift does not become permissible merely because it is disclosed.
10. Confidentiality and protection from retaliation
Conflict disclosures will be maintained in a restricted-access file and shared only with persons who need the information for review, oversight, legal compliance, or institutional administration.
The College will not tolerate retaliation against an employee who makes a good-faith disclosure, seeks guidance, or reports a suspected violation. Knowingly false statements, deliberate concealment, or misuse of the reporting process may be addressed under applicable College policies.
Confidentiality is not absolute where disclosure is required by law, a legitimate investigation, or an authorized governance process.
11. Failure to disclose or comply
Failure to disclose a conflict, providing materially misleading information, violating an approved safeguard, or improperly using College resources may result in corrective action or discipline, up to and including termination of employment, subject to applicable law and College procedures.
Before imposing discipline based on an alleged nondisclosure, the College should provide an appropriate opportunity for the employee to respond and should document the findings and corrective action.
12. Records and annual review
Human Resources or the designated compliance officer shall maintain:
Annual employee disclosure forms.
Requests involving specific transactions or outside activities.
Written determinations and conditions of approval.
Records of recusals and independent reviews.
Evidence of follow-up or corrective action.
Records shall be retained according to the College's records-retention policy and applicable legal requirements.
The College shall review this policy at least annually and revise it when necessary to reflect changes in law, institutional operations, governance, or accreditation expectations.
Appendix A — Employee Conflict of Interest Disclosure and Request Form
Community Christian College
Use this form for annual disclosures, new or changed circumstances, outside employment, related-party transactions, gifts, and requests for approval of activities that may create a conflict of interest.
COMMUNITY CHRISTIAN COLLEGE
Employee Conflict of Interest Disclosure and Request Form
Confidential Personnel / Compliance Record.
Section 1 — Employee Information
Employee Name: __________________________________________
Job Title: _______________________________________________
Department / Athletic Program: _____________________________
Supervisor: ______________________________________________
Date Submitted: __________________________________________
Type of Disclosure (check all that apply):
Annual disclosure
New or potential conflict of interest
Change in previously disclosed circumstances
Outside employment or business activity
Family or personal relationship
Vendor, purchasing, or contractual relationship
Gift, payment, or other benefit
Other: _____________________________________________
Section 2 — Description of the Interest
Describe the actual, potential, or perceived conflict of interest. Include the relevant people, organizations, businesses, and relationships.
Does the situation involve a financial interest or possible personal benefit to you or a related person?
Yes
No
Uncertain
If yes, describe the nature of the interest or benefit:
Does the situation involve a family member, household member, close personal associate, or business partner?
Yes
No
If yes, identify the relationship and explain its relevance to your College duties:
Does the situation involve College funds, contracts, purchasing, employment, student decisions, athletic operations, confidential information, or other College resources?
Yes
No
If yes, provide details:
Section 3 — Proposed Activity or Transaction
Describe the proposed activity, business arrangement, outside employment, purchase, contract, or other matter for which disclosure or approval is requested.
Estimated financial value, if applicable: $____________________
Expected start date: _______________________________________
Expected duration: ________________________________________
Your role in the proposed activity or transaction:
I will make or approve decisions.
I will recommend or influence decisions.
I will supervise or evaluate a person involved.
I will receive a financial or other personal benefit.
I will not participate in College decisions related to this matter.
Other: _____________________________________________
Section 4 — Proposed Safeguards
What steps do you propose to prevent an actual or perceived conflict?
Recusal from relevant decisions
Independent review or approval
Competitive bidding or independent price comparison
Change in reporting or supervisory arrangements
Restriction of access to confidential information
No use of College time, funds, facilities, or equipment
Other: _____________________________________________
Additional explanation:
Section 5 — Employee Certification
I certify that the information provided on this form is true and complete to the best of my knowledge. I understand that submitting this form does not automatically authorize the proposed activity or transaction.
I agree to disclose material changes, cooperate with the College's review, and comply with any conditions imposed by the College. I understand that failure to disclose a relevant conflict or comply with an approved safeguard may result in corrective action or discipline under applicable College policies.
Employee Signature: ______________________________________
Date: ___________________________________________________
Section 6 — Administrative Review
For Human Resources or the Designated Compliance Officer
Date Received: ___________________________________________
Reviewer: ________________________________________________
Additional information required?
Yes
No
If yes, specify:
Conflict determination:
No conflict identified
Potential conflict identified; safeguards required
Actual or perceived conflict identified; safeguards required
Request referred for higher-level review
Request denied or activity prohibited
Further review pending
Conditions or safeguards imposed:
Reviewer's rationale:
Section 7 — Final Authorization
Decision:
Approved without additional conditions
Approved subject to the conditions above
Denied
Referred to the President or Board of Trustees
Pending further review
Authorized Decision-Maker: _________________________________
Title: ___________________________________________________
Signature: _______________________________________________
Date: ___________________________________________________
Next Review Date, if applicable: ____________________________
Section 8 — Employee Acknowledgment of Decision
I acknowledge receipt of the College's written determination and understand that I must comply with the stated conditions.
Employee Signature: ______________________________________
Date: ___________________________________________________
Recordkeeping: Return the completed form to Human Resources or the designated compliance officer. Maintain the form and supporting records in the restricted-access compliance file in accordance with College records-retention requirements.