Ethical Obligations of Commission Staff

The Commission on Colleges and Universities staff members hold themselves to the highest standard of personal and professional conduct. In keeping with – and support of – The Commission’s commitment to integrity, staff members give particular attention to maintaining confidentiality, avoiding real and apparent conflicts of interest, and striving for consistency in their respective work with member institutions and the public. The Commission staff members should identify those member and applying institutions for which a potential conflict of interest exists. A conflict of interest exists if a The Commission staff member:

1. attended the institution.
2. was employed by the institution.
3. has been a compensated consultant at the institution within the last ten years.
4. has been an appointee of the institution within the last ten years (e.g., board member).
5. has been interviewed as a candidate for employment at the institution within the last ten years.
6. served on a review committee to the institution within the last ten years.
7. has an immediate family member who is attending or has attended the institution.
8. has an immediate family member who is or has been employed at the institution.
9. has a close relationship with persons at the institution or a strong bias regarding the institution.
10. is a stockholder of a publicly traded for-profit institution.

Furthermore, The Commission staff members should be sensitive to personal situations which might present conflicts of interest in their relations with member and applying institutions. In particular, staff members are prohibited from accepting honoraria, awards, or honorary degrees from member or applying institutions. No consultant fee may be accepted by The Commission staff from any applicant, candidate, or member institution.

Institutions accredited by The Commission may be publicly traded corporations or may be owned by publicly traded corporations. The actions that The Commission may take concerning these institutions may affect the stock price of these corporations. This fact necessarily imposes certain obligations on The Commission staff. A copy of this policy will be provided to all The Commission staff upon their employment.

[Publicly Traded Institution]. A Publicly Traded Institution is a corporation that is or that owns an educational institution which is a member of or candidate for accreditation by The Commission, the stock of which is traded on any public stock exchange. [Immediate Family]. An individual’s immediate family includes spouse, children, and parents.

[Direct or Beneficial Ownership.] Direct or beneficial ownership includes ownership in one’s name individually, through a closely held corporation or family partnership, by an individual retirement account or similar retirement vehicle, or by a trust. An individual is not considered a direct or beneficial owner of stock if that individual owns mutual funds that may own stock in a publicly traded institution. An individual is not considered a direct or beneficial owner of stock if that individual’s employer holds stock of a publicly traded institution in its endowment.

[Persons Subject to this Policy]. Persons subject to this policy are The Commission Employees and their Attorneys.

Obligations concerning publicly traded institutions the stock of which is owned by individuals. No person who is subject to this policy may take any action or serve in any capacity concerning a publicly traded institution the stock of which the individual or the individual’s immediate family owns directly or beneficially. Obligations concerning publicly traded institutions subject to action by The Commission. No person who is subject to this policy may disclose to any person who is not subject to this policy any information concerning any action or proposed action by The Commission concerning a publicly traded institution except through a means that makes the disclosure available to the general public at the same time; provided however, that The Commission may disclose such action or proposed action to representatives of the publicly traded institution in advance of the public disclosure.

Obligations of The Commission staff. The Commission staff shall make available to persons subject to this policy at least annually a list of all publicly traded institutions.

The Commission staff members will affirm in writing their adherence to this policy upon their employment, and the signed “Conflict of Interest Statement for The Commission Staff Members” will be housed in the personnel files maintained by the Office of Human Resources. If this policy is revised, staff members will be required to update their files by signing and affirming their adherence to the revised policy. Any full- or part-time employee of The Commission is considered a staff member. The Commission staff members who work directly with member institutions will also maintain a record of their conflicts of interest in The Commission database.