8.1 Conflict of Interest Policy

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This online version is for convenience; the official version of this policy is housed in the University Secretariat. In case of discrepancy between the online version and the official version held by the Secretariat, the official version shall prevail.

Approving Authority: President

Original Approval Date: June 8, 1995

Date of Most Recent Review/Revision: February 2, 2026

Office of Accountability: Office of the President and Vice-Chancellor

Administrative Responsibility: University Secretariat

1.00 Purpose

1.01 The purpose of this policy is to define what constitutes Conflicts of Interest and establish principles and procedures for Employees and Volunteers in the identification, disclosure, and management of Actual, Potential, or Perceived Conflicts of Interest.

1.02 This Policy is intended to protect the integrity and impartiality of University decision-making and the responsible use of University resources, and to maintain confidence in the University’s operations and conduct. Adherence to this policy will ensure that Employees and Volunteers act fairly, ethically, and in the best interests of the University.

2.00 Definitions

2.01 Conflict(s) of Interest: occurs when Personal Interests interfere, or are perceived to interfere, with the independent judgment required by Employees and Volunteers to perform their duties and responsibilities in the interest of the University. Conflicts of Interest are generally divided into the following categories:

a. Actual Conflict of Interest: a situation where a Personal Interest actually conflicts with the Employee or Volunteer’s obligations to or role in the University and may result in the opportunity to further their Personal Interest.

b. Potential Conflict of Interest: a situation where an Employee or Volunteer has a Personal Interest that could influence the performance of their duties or responsibilities as an Employee or Volunteer, provided that they have not yet exercised that duty or responsibility.

c. Perceived Conflict of Interest: a situation where a reasonably well informed and impartial person would believe that an Actual or Potential Conflict of Interest exists on the part of an Employee or Volunteer, whether or not such a Conflict of Interest exists.

2.02 Employee(s): a person who performs work for wages in any capacity for the University.

2.03 Family Member: includes a person’s spouse, common law partner or adult interdependent partner, or another individual to whom the person is related by blood, marriage or adoption (i.e. parents, stepparent, foster parent, adoptive parent, siblings, child by blood, adoption, or marriage, grandparent or grandchild, etc.)

2.04: Financial Benefit/Interest: an Employee or Volunteer has a financial interest where they or a Related Party can benefit from a decision made by the University. The interest or benefit may take the form of money, Gifts, Favours or other special considerations. It involves an actual, potential or perceived financial gain or loss. Money does not need to change hands for an interest to be financial. For example, Employees have a financial interest if they or a Related Party own property being considered for purchase or lease, hold shares or have a position in a company bidding for work, hold or expect to receive intellectual property rights (e.g. patents, copyrights, royalties or carried interests or options related to such rights), or receive benefits such as employment opportunities, concessions, discounts, gifts or hospitality from a particular source related to the decision of the University.

2.05 Gift(s)/Favours: include tokens of appreciation, entertainment, travel, hotel accommodations, services for personal use, reduced prices for goods and/or services for personal use, and work done for the individual at home or elsewhere. Gifts and Favours also include any hospitality or gifts given by an individual or organization in the hopes of garnering favour for the future purchase of products or services by the University.

2.06 Manager: A person who has charge of a Workplace or authority over an Employee or Volunteer.

2.07 Nepotism: may include, but is not limited to, participating in or influencing the hiring, promotion, supervision, evaluation, compensation, or benefits of a Family Member.

2.08 Non-Arm’s Length Relationship: a relationship between individuals connected by blood, marriage, adoption, or otherwise. A non-arm's length relationship may also exist between individuals and partnerships or corporations.

2.09 On Duty: an Employee or Volunteer is considered on duty any time they are conducting University business and undertaking duties and responsibilities associated with their work.

2.10 Personal Benefit/Interest: is a Financial, professional/career or other private interest of the Employee or Volunteer or their Related Party. This does not include an interest in a matter that is of general application, or an interest in a matter that affects the Employee or Volunteer as one of a broad class of the public or an interest which is immaterial, insignificant or inconsequential with respect to the interest of the University.

2.11 Personal Relationship: any Non-Arm’s Length Relationship, including but not limited to Family Members and persons with whom there is, or has recently been, a close personal relationship.

2.12 Related Party: a Family Member, or other person living in the same household, or any persons with whom there exists or has recently existed a close Personal Relationship, or any other person with whom the Employee or Volunteer shares a Financial Interest (either directly or indirectly), or any entity in which the Employee or Volunteer has a material ownership interest.

2.13 Significant Conflict of Interest: A Conflict of Interest that exposes the University to significant financial or reputational risk.

2.14 Volunteer: individuals who willingly provide services or assistance to the University without payment of fees, wages or salary and without any expectation of any kind of compensation other than reimbursement for expenses incurred or, as may be applicable, a pre-approved honorarium.

2.15 Workplace: Any site at which an Employee or Volunteer works, including any property or buildings owned, leased or managed by the University, and any other place an Employee or Volunteer is located while performing work for the University or while representing the University. This includes operating University equipment or a personal vehicle when the employee is On Duty.

3.00 Jurisdiction/Scope

3.01 This policy applies to all Employees and Volunteers who perform University-related activities on and off campus.

3.02 This policy does not apply to members of the Board of Governors, who are subject to Policy 14.2: Conflict of Interest Policy for the Board of Governors, and its related procedures.

3.03 Nothing in this policy shall limit, supersede, or replace obligations arising under collective agreements or applicable legislation.

4.00 Policy

4.01 Employees and Volunteers shall avoid, whenever possible, any situation in which their Personal Benefit/Interest could improperly influence, or be perceived to influence, their University responsibilities and must take reasonable steps to avoid Actual, Potential, or Perceived Conflicts of Interest.

4.02 Conflict of Interest situations can be direct or indirect, meaning that the situation may affect not only the Employee or Volunteer but also a Related Party

4.03 Employees and Volunteers shall not use their position, authority, or access to information for Personal Benefit/Interest. They shall protect confidential University information and use University resources only for authorized purposes.

4.04 While moderate hospitality is an accepted courtesy of a business relationship, the frequency and scale should not be greater than what the University would be able to provide in return. Employees and Volunteers shall not accept Gifts/Favours that influence or may appear to influence their or the University’s activities, affairs, or decision making, or offer Gifts/Favours in order to secure preferential treatment for the University.

4.04.01 Gifts and Favours valued in excess of $250 shall not be accepted from external individuals or organizations. This includes smaller gifts from one individual or organization that when totaled, are in excess of $250 dollars over the course of a year.

4.04.02 Gifts and Favours to individuals or organizations that utilize university funds or facilities must adhere to the Expense Handbook.

5.00 Disclosure of Conflicts of Interest

5.01 Employees and Volunteers are required to disclose Actual, Potential, or Perceived Conflicts of Interest in writing to their Manager as soon as they become aware of such conflicts. Disclosures shall be made in writing, in accordance with the procedures for this policy.

5.01.01 Without limiting the generality of the foregoing, Employees or Volunteers are required to disclose any situation involving Nepotism or the potential for Nepotism.

5.01.02 If a Manager is implicated or has a material interest in a Conflict of Interest, the matter shall be referred to the next highest-level Manager. If the President and Vice-Chancellor or the Chancellor is implicated, the matter shall be referred to the Chair of the Board of Governors. If the Chair of the Board of Governors is implicated, the matter shall be referred to the Vice Chair(s) of the Board of Governors and the Assistant Vice President, Governance and Policy.

5.02 Employees and Volunteers are required to make active and ongoing disclosures to ensure Conflicts of Interest are appropriately managed.

5.03 Disclosure is required even where the individual believes the Conflict of Interest can be managed or does not influence their judgment.

5.04 If an Employee or Volunteer is unsure whether they are in Conflict of Interest, they should report the matter to their Manager. If the Manager is unsure about whether the matter constitutes a Conflict of Interest, they may consult other entities within the University as appropriate (e.g. Office of Legal Services and Fair Practice).

5.05 Where a Volunteer or Employee serves on a committee, Conflicts of Interest must be disclosed to the committee chair, with a copy to the recording secretary for documentation. If the chair is conflicted, the disclosure must be made to the committee’s vice-chair (or other designated alternate) and the recording secretary. Where there is no vice-chair, the matter shall be referred to the Office of Legal Services and Fair Practices.

5.06 Disclosure of a Conflict of Interest does not imply wrongdoing. Holding a Personal Interest or engaging in external activities does not, in itself, constitute a Conflict of Interest.

5.07 Third-party disclosures of undeclared Conflicts of Interest shall be dealt with in accordance with Policy 5.14: Safe Disclosure.

6.00 Managing Conflicts of Interest

6.01 Managers are obligated to identify Actual, Potential, or Perceived Conflicts of Interest with respect to the Employee or Volunteer who reports to them.

6.02 Upon the disclosure or identification of Conflicts of Interest, Managers or committee chairs shall review and manage them in a manner that is fair, consistent, and proportionate to the nature of the Conflict of Interest.

6.03 A Conflict of Interest may, in certain cases, be permitted when it can be managed in a way that is compliant with legislation; considers, protects and serves the interests, integrity and reputation of the University; and will withstand the test of reasonable and independent scrutiny.

6.04 Where a Conflict of Interest is determined to be manageable, the related activity may proceed with written authorization by the Manager, with appropriate approval escalation as may be necessary and set out in this policy and the procedures, subject to any conditions set out in the written management measures.

6.05 Management measures for Conflicts of Interest may include conditions, restrictions (e.g. recusal from discussions and decisions), modification of duties (e.g. reassignment), or other reasonable measures as set out in the procedures for this policy.

6.06 Management decisions shall be communicated in writing to the Employee or Volunteer who has a declared or identified Conflict of Interest.

7.00 Appeals

Employees and Volunteers may appeal management decisions regarding Conflicts of Interest in accordance with the procedures for this policy.

8.00 Retaliation and Reprisal

The University will not tolerate any retaliation or reprisal, through any means, against anyone who discloses a Conflict of Interest, or who participates in a University process that is addressing a disclosure or report of a Conflict of Interest. Retaliation or threat of retaliation or reprisal may result in disciplinary action under this or other University policies.

9.00 Confidentiality, Privacy and Record Management

9.01 No individuals involved in the disclosure or identification of a Conflict of Interest shall disclose or discuss the details of the conflict or management decisions with anyone other than those personnel associated with the University who know such details and results, in order to perform their duties and responsibilities. Matters concerning Conflicts of Interest shall be kept confidential within the limitations of the law, collective or employee agreements and University policies.

9.02 All written records pertaining to Conflicts of Interest shall be retained in accordance with Policy 10.4: Information Governance, and the procedures for this policy.

10.00 Non-Compliance

Conflicts of Interest that go undisclosed, or that are improperly managed, may have negative consequences for an Employee, Volunteer, and/or the University, and could undermine public confidence in the institution.

Accordingly, non-compliance with this policy, including but not limited to: a) non-compliance with any management measures imposed under Section 6, or b) the occurrence of a prolonged and undeclared or unmanaged Conflict of Interest, may result in consequential measures in accordance with applicable University policies, procedures, and collective agreements.

11.00 Reporting

11.01 All disclosures and management resolutions regarding Significant Conflicts of Interest shall be reported to the Office of Legal Services and Fair Practices.

11.02 The Office of Legal Services and Fair Practices shall make an annual report on Significant Conflicts of Interest to the Audit, Risk, and Compliance Committee of the Board of Governors.

Related Legislation

Broader Public Sector Accountability Act, 2010, S.O. 2010, c. 25