Conflict of Interest Policy

 
Document Number:
HR-10041
Status:
Published
Revision #:
Rev1.1
Published / Last Updated Date:
7/21/2022

General Information

Purpose:

Tyndale University's mandate includes a commitment to operate with the highest level of integrity and to avoid conflicts of interest that either directly or indirectly result in material personal advantage or privilege.

Scope:

This policy applies to all Governors, Employees and Volunteers of the University
 

Terms and Definitions:

Term:

Definition:

Actual Conflict of Interest
Circumstances that may arise in decision making, or contractual commitments made on behalf of Tyndale where the individual does not deal at “arm’s length” and may:
  • realize a direct or indirect gain of a commercial nature,
  • receive money or property
  • receive a direct or indirect significant advantage or privilege in connection with any such transaction or significant relationship
  • employ a family member directly or with an organization where a family member is employed

Apparent Conflict of Interest
A situation that causes an observer or third party to question whether the decision maker can be objective or impartial because of a competing interest where he or she may have dual allegiance.
Employees
Full-time and part-time faculty and staff (including student workers)
Governor
An individual who is part of the Board of Governors of the University
Officer
An employee or governor with Board-appointed authority to bind the University or carry out certain duties on behalf of the University.
Supervisor
The individual to whom a person is accountable. This could include, but not be limited to the following relationships: Individual Employees report to their managers, directors, or executives. Executives or Cabinet Members are accountable to the President. The President is accountable to the Board of Governors. Individual Governors are accountable to the Board of Governors.
Volunteers
An individual that contributes services to Tyndale without compensation.
 

Responsible Department or Functional Area:

Human Resources

Audience(s):

*All Employees
Board
Volunteeers
Regulations

Act/Regulation:

Canadian Centre for Christian Charities Accountability Standards
Policy Provisions
  • 1

    Description:

    Individuals working with the University (whether remunerated or not) must avoid actual or perceived conflicts of interest that may bring into question the objectivity of decisions which they make or participate in on behalf of Tyndale.
  • 2

    Description:

    Governors, Officers and Cabinet members will be required annually to attest compliance with this policy 
  • 3

    Description:

    At every Board and Cabinet meeting those Governors, Employees and Volunteers in attendance must declare actual or perceived conflicts of interest with items that are on the agenda.  Any declarations are required to be part of the meeting minutes.
  • 4

    Description:

    Governors, employees and volunteers must, on an ongoing basis, review their outside interests and relationships for actual or perceived conflicts of interest. As soon as they become known, individuals are required to disclose this information to their supervisor and to complete the prescribed form.
  • 5

    Description:

    When actual or perceived conflicts of interest are attested to or declared, a determination must be made about how the actual or perceived conflicts will affect the individuals participation, work or involvement in decision making.  This may include but is not limited to the individual recusing themselves from the decision-making process or working relationship. The primary concern must always be the welfare of the University and the advancements of its purposes.

    The decision on how the actual or perceived conflict of interest will be handled must be documented either through the prescribed form or become part of the meeting minutes.

    Scope and Exceptions:

    The final determination of whether a conflict of interest exists remains with the University in its sole discretion.
  • 6

    Description:

    The existence of a perceived or actual conflict of interest does not necessarily mean that the conflict is objectionable, or significant enough to be of practical importance, or that it is necessarily averse to the interests of the University or its charitable purposes. However, the existence of any perceived or actual conflict of interest must be disclosed and evaluated before any transaction or action is carried out. If a Governor, Employee, or Volunteer has any doubt, or has questions of interpretation, the individual’s supervisor should be consulted.
Related Documents
Performance Evaluation

Consequences of Policy Violation:

Violations of this policy may constitute grounds for dismissal from employment or volunteer roles, including the role of Governor.

Example Violations:

Areas where conflict of interest may arise include but are not limited to:
  • The acquisition or supply of goods or services.
  • The acquisition or granting of property and equipment leases.
  • The investments made by Tyndale.
  • Business dealings with donors.
  • Dealings with any other individuals, agencies, organizations, companies, governments or associations that affect the purpose or operation of Tyndale.
where the individual is not dealing at arm's length and:
  • has a significant interest in any business which deals with Tyndale or an Affiliate.
  • is engaged in a professional practice which provides services to Tyndale or an Affiliate organization.
  • is a Governor or an Employee of Tyndale while serving on the board or holding an office in any entity that has dealings with Tyndale or an Affiliate.
  • provides goods or services to Tyndale or an Affiliate for consideration, while serving as a Governor, Officer, Employee or Volunteer of Tyndale or an Affiliate.
  • receives any compensation, whether cash, goods or services, from any business, charity or individual where such compensation is provided as a direct or indirect result of a relationship established through Tyndale or an Affiliate.
  • uses Tyndale's or an Affiliate's personnel, equipment, supplies, name, publications, or other resources for non-Tyndale purposes outside of established policy.
  • receives personal gifts or loans from any third parties having dealings with Tyndale or an Affiliate given as a direct or indirect result of the Tyndale relationship.
  • has an interest in real estate, securities or other property that Tyndale or an Affiliate has an interest in buying or leasing.
 

Primary Author / Owner:

Name:

Email:

Admin & Support Services Senior Vice President
[email protected]