Policies & Procedures

I. PURPOSE

The purpose of this policy is to provide guidance to employees and officers relating to conflict of interest and to inform them of their duty to comply with the State and Local Government Conflicts of Interests Act (Code of Virginia § 2.2-3100 et seq.).

II. DEFINITIONS

1. Employee: All persons employed by Longwood University in any capacity.
2. Officer(s): Members of the Longwood University Board of Visitors, both individually and collectively.

III. POLICY

1. Statute: The citizens of the Commonwealth are entitled to be assured that the judgment of public officers and employees will not be compromised or affected by inappropriate conflicts. The State and Local Government Conflict of Interest Act (Section 2.2-3100etseq.) and the Virginia Public Procurement Act(specifically Section 2.2-4367 et seq.), provide the body of law applicable to all Longwood employees and officers regarding such conflicts. The entire law is not summarized in this policy; however, employees and officers should be aware that the following situations may represent violations:
   1. Soliciting or accepting money or gifts:
      1. except allowable expenses, employee compensation or other remuneration paid by the university;
      2. for compensation for obtaining employment, an appointment or promotion of any person with any government agency;
      3. for consideration of the use of your public position to obtain a contract for any person/business with any government agency; or
      4. that may tend to influence you in the performance of your official duties.
   2. Accepting any business/professional opportunity that is being afforded to you to influence you in the performance of your official duties.
   3. Using any confidential information for your or another party's benefit that you have acquired by reason of your position and which information was not available to the public.
   4. Having a personal interest in a Longwood agreement/contract other than your contract of employment.
   5. Having a personal interest in a contract with another state agency that was not awarded through a competitive process.
   6. Involvement by you or a member of your immediate family in any manner in a Longwood procurement transaction while at the same time negotiating/arranging for prospective  employment with that bidder or offeror.
   7. While involved in any manner in a procurement transaction, soliciting or accepting any money, service or anything of value from any bidder or offeror, contractor or subcontractor, unless consideration of equal/greater value is exchanged.
2. Compliance Questions: The cited Code of Virginia sections should be consulted by any employee or officer who may be involved in any such situation as summarized above. The Code may be accessed at http://leg1.state.va.us/000/src.htm.  Employees who have questions should consult with the Human Resources Office. Officers who have questions should consult with the Attorney General’s Office.

IV. ENFORCEMENT

If an employee or officer has reason to believe a violation of the policy exists, it is his/her duty to report it to the Internal Auditor. It is the responsibility of the Internal Auditor to investigate any allegations of violation of this policy.

Approved by the Board of Visitors, September 7, 2002.
Revised and approved by the Board of Visitors, December 07, 2007.
Reviewed and Approved by Cabinet, February 28, 2013.
Revised and approved by the Board of Visitors, March 22, 2013