In 2c it just says approval from vice president, but later it states vice president or provost.

I am curious as to why "6. Public Service
The college encourages public service activities that are not incompatible with full performance of college duties and not inconsistent with college policies and procedures." was removed ? As a state institution, I would encourage our employees to seek public service opportunities and support our employees who serve in public service roles (boards, office, etc) as it serves our institution and our state.

It looks like consulting days were removed as an option. I am opposed to this change. I know the consulting I have done previously have been focused on external activities that further the college mission and goals. I am a volunteer with the organization that develops the accredidation exam for my profession. By consulting for this organization I gain a greater insight that allows me to better help my students. I know other faculty and staff who participate in similar activities. This is going to reduce our involvement in our community and impact the college's goals.

3. Definitions E appears to be a typo.
4. A. 2(c) and 3 (Conflict of Interest ) - Are these sections intended to imply that written authorization is required from the VP and PWC must be notified, even if it is determined no COI exists by the supervisor? Currently says "actual, potential, or apparent conflict of interest" triggers these actions.
4.B.5.d (Research Projects Serving External Interests). It is important to note that any activity that poses or potentially poses a conflict of interest to a sponsored project MUST be brought to the attention of the Office of Sponsored Projects to ensure the guidance of the sponsoring agency is taken into account. OSP will evaluate the COI or potential COI, review the sponsor guidance, and determine if the agency must be notified, and if the conflict affects the PIs ability to continue on the research project from the perspective of the sponsoring agency.

C. External Employment, Consultation, and Other External Activity
1. General
a. actual or potential conflict of commitment; b. actual or potential conflict of interest which may adversely impact the employee’s allegiance to the college; c. appearance of a conflict of interest or inappropriate appearances; and d. activity that is inconsistent with the college's mission, vision, values, and goal.

My concern with some portions of the proposed policy (external employment and consulting) is it is subjective to an interpretation of potential conflicts of interest or appearance (C.1.c, d).
I engage in consulting and private business that may be viewed by some, depending on their feelings, as being contrary to some of these policies through either appearance or actual practice. In the past, I've made public comments based on my experience and (past and current) to the media and to consulting organizations that were questioned by some people within the college. This last week, I saw a public-school teacher make comments to the media about a public issue based on their experience and I would hate for someone who has an opposite political feeling to act against this teacher for what he did. He was standing up publicly on an opposite side of an issue that has garnered significant public opinion. I can think of other things I do within my private business that someone could take issue with based on a perceived conflict. I want to make sure that as our cultural & political temperature changes from one side to another, this policy is not used subjectively against employees that have practiced consulting or private businesses in the same manner for years and even decades.

Limiting consulting to 24 days per year is an over-reach. Many faculty had consulting businesses before becoming Professors. If faculty decide to take summers off, there are more than 24 potential days to consult during the summer that do not interfere with contract hours.

The wording is fiscal year and not academic year. It should also not apply if the faculty is off-contract.

Also, Ph.D. students who are also faculty will have research projects as part of their Ph.D. program. Some of the research limitations and permissions are over-reached.

If the research is part of a degree-seeking program (Ph.D.), the faculty should not need permission from the college to continue research.

There is a lot of conflicting messaging within this and the expectations for the tenure process. As faculty, we are expected to have Professional Activity and Professional Development, but this convolutes the process and makes it incredibly difficult to meet the expectations with the restrictions.

Why are we making these processes harder and not smarter?

3. Definitions
a. Section 3. Consider adding the term “Conflict of Interest” to the definitions. Since this is the Conflict-of-Interest policy, it seems like there should be definition for this term. It is a bit confusing with the use of Conflict of Commitment term.
b. Section 3. Consider adding the term “College Data” to the definitions. This term is used in 4.B.5.d. Is this aligned with the Data Governance policy?
c. Section 3. Consider adding “Insider Information” to the definitions. This is used in section 4.B.3.
d. Section 3.A. Conflict of Commitment. The policy is called the Conflict-of-Interest policy, but the policy uses the term Conflict of Commitment. This is confusing. What is the difference between Conflict of Interest and Conflict of Commitment?

4. Procedure
A. General
1. In Section 4.A.1.b, it states that the expectation of an employee is to “avoid any activity or work pattern that lowers productivity and effectiveness” This phrase, as drafted, is overly broad and vague and may constitute an unreasonable expectation. For example, would staying up until midnight before teaching an 8:00 am class violate this provision? Consider changing the wording so that it reads “reasonably avoid any activity or work pattern that lowers productivity and effectiveness.”
2. In Section 4.A.2, the title of this section is: “Conflict of Interest Prohibition and Disclosure” yet the policy does not define Conflict of Interest. Rather, 4.A.2.b references “conflict of commitment.” This inconsistent use of the terms conflict of interest and conflict of commitment occurs throughout the policy and should be corrected. As drafted, this may create confusion.
3. In Section 4.A.2.a, it states: “All employees are prohibited from any conduct that creates actual, potential, or apparent conflict of interests between the College and the employee.” The question was asked, if an employee files a grievance against the college, does that constitute a conflict of interest or commitment?” Would a grievance then be a Conflict-of-Interest policy violation?
4. In Section 4.A.2.b. it states “Employees must disclose in writing all actual, potential, and actual conflicts…” How is the employee to do this? An email, memo, a specific form? How is it to be submitted, and to whom? Consider providing clarification to this section by adding a link for the Conflict-of-Interest Disclosure form.
5. In Section 4.A.2.b, it states “… apparent conflicts of interest or commitment or manage to eliminate such conflicts as provided in this policy” Consider replacing “or manage to eliminate such conflicts as provided in this policy” with “to their supervisor and appropriate vice president.”
6. In Section 4.A.2.c, it states: “After disclosure of an actual, potential, or apparent conflict of interest to the supervisor and appropriate vice president…” What if the supervisor and the employee disagree on whether there is a conflict of interest? How is this dispute addressed? One solution proposed is to consider revising this to read “…supervisor or vice president….”
7. In Section 4.A.2.c., the process of reporting a Conflict of Interest to the supervisor and vice president seems onerous because it requires reporting it to two people. Can this be changed to supervisor or vice president?
8. A section should be added to allow for a Conflict-of-Interest determination to be appealed.

B. Types of Conflict of Interest
1. In Section 4.B.4.a.(2), it states “An employee may accept an occasional nonmonetary gift provided the value is at most $50.” Consider adding language to clarify that the gift is not a result of business dealings (not a bribe).
2. In Section 4.B.4.b.(2), it states: “secure privileges not available to all college employees from outside organizations or persons; or” Consider adding language “unless it is part of their employment benefit or compensation package approved by PWC.”
3. General Comment on Section 4.B.4.b(2). The Committee has an extensive discussion on reported practices in the SLCC Daycare Center and at the LAC. In both departments, it appears that daycare employees and assistant coaches who coach club teams not related to the college get a discount. For daycare employees, they receive a discount for childcare. For coaches, they effectively receive a discount for use of the LAC. These discounts are not available to all college employees.

Regarding the daycare discount, the committee opined that given the low wage amount paid to daycare employees, this the discount was necessary to attract qualified employees. In addition, the committee also believed that since daycare discounts are common in the daycare industry, that SLCC’s failure to provide daycare employees a discount could result in SLCC losing qualified daycare employees to other daycare centers.
Further research at other USHE institutions showed that Utah State provided a 20% discount for all employees. Meanwhile, Weber State provided a $2 per hour discount.
The committee felt that a satisfactory solution to this problem was to make this discount an employee benefit. Consequently, the committee proposed adding language to this section which states: “unless it is part of their employment benefits or compensation package approved by PWC.”

As for the practice in the LAC, the Committee believed these discounts were different than for daycare employees. The rationale was that SLCC assistant coaches coaching an AAU or club team are engaged in an activity external to the college. In addition, in most of the cases, this club team is a revenue generating activity for the coach. Thus, the committee did not believe that this circumstance was like the daycare circumstance.

4. In Section 4.B.5.a.(1), it states that an employee must disclose to their supervisor if they “are engaged in research or other projects within both the college and other organizations; or and”. Consider excising “within the college and” because this policy section is only dealing with external interests in this section. Since faculty research is often done with a third party, it should not be subject to the Conflict-of-Interest policy unless there is some type of personal business interest or pecuniary gain involved. For example, when we do work with Granite School District, we are helping the School District as well as the College. Should that type of work be covered by the conflict-of-interest policy?

5. In Section 4.B.6.a.(2), it states: “refrain from usurping the opportunity for their personal gain or interest.” The word “usurping” may be difficult for some to understand, and this may be an equity issue. Consider instead using the word “seizing.”

C. External Employment, Consultation, and Other External Activity 1. General Comment: It has come to the Committee’s attention that there may be a desire to delete the Consultation portion of this policy. The rationale for this proposed deletion is unclear. While the Committee may support some revisions to this section, it is unanimous that the Consultation section should remain in this policy.

By and large, many staff who conduct external consultations try to do this consultation in a manner that it does not interfere with their job duties. Consequently, this policy, as drafted, does not reflect the way consultations are generally practiced at the college.

Both faculty and staff committee members discussed both paid and volunteer consultations that they and co-workers participated in. These external consultations include: 1) conducting program reviews for other institutions; 2) sitting on the board of directors of a not-for-profit organization; 3) paid professional work in their area of expertise.

Faculty cited the AFPRT policy to support the Consultation subsection. In AFPRT policy, section 4.B sets forth Standards of Professional Responsibility such as “full-time faculty members committee to serve their students, their colleague, and the college in a manner befitting an academic person.” These consultations, whether paid or unpaid, were deemed essential for: 1) professional development; 2) maintaining fresh teaching material; 3) retaining licensure; and 4) provide service to the community.

The Committee unanimously supported the principles for the Consultation subsection. However, the Committee did have some recommended revisions, comments, or questions.

2. In Section 4.C.4.b. it states that “Employees may consult up to five consecutive business days at any one time but cannot exceed 24 days in one fiscal year.” Does this apply to partial days as well as full days? In other words, if one uses two hours in a day for consultation, does that count for an entire day? If the consultation does not interfere with the regular workday, is it an issue?

3. In Section 4.C.4.b.(1), it references a “Consulting Request form”. There is no link to this form, and it cannot be found on the website. This form should be linked to the policy, it is referenced several times throughout the policy.

4. In Section 4.C.4.b.(3), it states that “Employees must indicate… the consultation times and dates…” on the Consulting Request form. Sometimes it is difficult to get exact times and dates. Consider using text which is more flexible.

5. In Section 4.C.4.b.(5), do faculty need to take a full day off for consultation on contract days if their consultation only takes a short period of time? What if the faculty member has already worked a full day?

6. What is the difference between External Employment and Consulting? It is likely that a considerable percentage of employees have a second job. If an employee works at Lowe’s on the weekend, do they need to obtain supervisor approval?

7. If I consult from my office via laptop for one hour per day, is that considered external consulting?