Conflicts of Interest and External Activities (Paid, Volunteer, & Political)

Policy Ethics

This policy was adopted by the President of the College on October 1, 2025, and distributed for immediate implementation.

Introduction

Dalton State College (DSC) is a public institution operating as part of the University System of Georgia (USG). As such, DSC employees are subject to multiple policies governing their conduct to include policies governing conflicts of interest1, compensated outside employment2, and conflicts of commitment3.

Institutionally, DSC is expected to collaborate with the private sector and other third-party entities in support of our mission; however, the “resulting relationships and agreements … must not undermine the public’s trust, compromise the integrity of [our] mission, or inappropriately influence teaching, research, and service activities”4.

Conversely, DSC employees are expected to put DSC’s interests and the DSC mission first and avoid external activities that, in fact or appearance, would damage the public’s trust or compromise our teaching, research, and service mission. For all employees, this is understood to mean properly disclosing and avoiding and/or managing – with appropriate institutional approval – both real and apparent conflicts of interest. For full-time employees, this means seeking approval for compensated outside employment and avoiding conflicts of commitment5. Various USG Board of Regents (BOR or Board) policy provisions address political activities and these requirements also are outlined in this DSC policy.

DSC’s policy incorporates relevant Board Policies by reference. Incorporated under the term “Board Policy” or “BOR Policy” includes formal policies adopted by the Board of Regents and further policy and procedure guidance contained within the various USG manuals such as the Human Resources Administrative Practices Manual (HRAP), the Business Procedures Manual (BPM), etc. Further, the various definitions and explanations contained in the policy language, definitions, footnotes, etc., are considered part of the policy. Delegations of authority are outlined in DSC’s policy on delegated authorities.

DSC shall provide training and offer guidance on conflicts of interest and conflicts of commitment sufficient to ensure that all faculty and staff are aware of these ethical and compliance-related expectations. New faculty and employee orientation, Ethics Awareness Week activities, campus assemblies and other venues shall be utilized to ensure DSC employees are aware of these expectations.

Key Policy Provisions

1. Conflicts of Interest

The primary focus of this policy is individual conflicts of interest impacting DSC employees. Also outlined is the policy on institutional and research conflicts of interest.

Conflicts of interest, real and apparent, have the potential to call the public trust into question – particularly if the public believes that DSC employees are using their official position to further their personal (to include financial, familial, and business) interests. Serving the public as a DSC employee does not require a giving up of personal interests; however, it does require heightened diligence and care alongside disclosure – and potentially a formal conflict management plan – to ensure that DSC and its employees maintain that public trust.

DSC’s policy is designed to ensure periodic re-examination of our personal interests viewed in light of our DSC role in order to ensure we are continuing to maintain that public trust and the appropriate respect associated with our role as state employees and public servants.

Requirements
  • Avoid & Disclose – All DSC employees must avoid improper conflicts of interest and must disclose potential and/or apparent conflicts of interest. This requirement is an ongoing responsibility.
    • For example6, state law (Official Code of Georgia Annotated (O.C.G.A.) § 45-10-23) generally prohibits DSC employees from contracting with DSC or any USG entity either directly (excluding their employment contract) or through a business owned, partially owned (25% or more), or otherwise controlled by them or a family member (spouse or dependent)7. Engaging in such a contract would violate state law and be an impermissible conflict of interest in accordance with DSC policy.
    • For further example, O.C.G.A. § 45-10-26 requires DSC employees to disclose contracts / payments between other State of Georgia agencies and a business owned, partially owned (25% or more), or otherwise controlled by them or a family member (spouse or dependent). This is an example of a required disclosure of a potential conflict of interest.
  • Regularly Evaluate & Annually Disclose – There are various straightforward examples of impermissible conflicts of interest, e.g., employing a relative within your chain of authority as prohibited by Board Policy 8.2.3, violating the various State of Georgia statutes as enumerated in O.C.G.A. § 45-10-20 through § 45-10-70, accessing a family member’s academic record and changing a grade, providing inside information to a vendor seeking a contractual relationship with the institution, etc. To ensure compliance with this policy, all DSC employees should – at a minimum – evaluate any potential conflicts of interests on an annual basis and disclose those through the DSC conflict of interest disclosure process. Further, the annual disclosure will include an affirmative statement that no conflicts of interest requiring disclosure currently exist. (An annual disclosure process does not relieve a DSC employee from avoiding improper conflicts of interest nor should it be interpreted to mean that an employee only must consider disclosure once per year.)
    • The following is offered to assist DSC employees in considering potential conflicts of interests that should be disclosed. The previously-listed prohibitions are fairly obvious and straightforward. More complex situations may arise in the course of employment at DSC – particularly given the communities in which we serve and the interconnectedness of the many businesses, non-profits, and personal and familial connections that naturally arise as part of living in a close-knit community. While not exclusively true, the situations requiring the greatest scrutiny generally reflect three attributes, i.e., 1) exchange of items of value, 2) proximity to the work of the College and an employee’s own work at the College, and 3) affinity or the closeness of the related party that may be involved.
      • With respect to items of value, this could take the form of contracts, employment, gifts8, etc.
      • With respect to proximity and affinity, consider for example a DSC employee who is authorized to contract with a hotel to provide lodging for a campus event. If that employee’s spouse (affinity) manages, but does not own, the local hotel selected (proximity), this would represent a conflict of interest requiring disclosure and management. It may be that the hotel is the only available option, and the spouse receives no bonus or other remuneration tied to hotel bookings; even in that instance, the employee’s supervisor may need to handle the hotel selection to avoid the appearance of a conflict of interest. By the same token, the hotel should not be unfairly excluded from consideration solely because a DSC employee’s relative is employed there – this would detrimentally impact DSC employees insofar as local businesses would understandably be concerned with hiring spouses and dependents. For a related example, let’s assume the employee’s cousin works the front desk at the same hotel chain but in another city. The affinity and proximity in this instance likely would not require a conflict of interest disclosure. A middle course might feature an adult child who works at the local hotel as a waiter; in this instance, the DSC employee may wish to verbally disclose to their manager, but a formal written disclosure likely would not be required.
    • Reasonable Person View – Every situation is different; however, the expectation is that employees keep front of mind the definition of a conflict of interest previously shared, i.e., “when a reasonable person would conclude from the circumstances that the employee’s ability to protect the public interest, or perform public duties, is compromised by a personal, financial, or business interest.”
    • Research and Institutional Conflicts of Interest – DSC recognizes the benefits of collaboration and commercialization with the private sector and other third-party entities that support DSC’s mission. The resulting relationships and agreements, however, must not undermine the public’s trust, compromise the integrity of the DSC mission, or inappropriately influence teaching, research, and service activities. Under no circumstances should a grant, gift, contract or other funding be accepted that limits the ability of DSC employees to conduct or report the results of research in accordance with applicable scientific, medical, professional, and ethical standards. (Process Note: The DSC Executive Cabinet is responsible for reviewing proposed grants, gifts, contracts, and other funding to ensure compliance with this policy.)
Process
  • Employee: Any potential conflicts of interest should be verbally disclosed as soon as practicable to an employee’s supervisor.
  • Supervisor: The supervisor should provide guidance, in consultation with HR as needed, as to whether the employee should complete a formal conflict of interest disclosure form.
  • Employee: Employee should follow their supervisor’s guidance with respect to managing the conflict and/or submitting the Conflict of Interest form for more extensive review and approval.
  • Vice President (President): Before approving the Conflict of Interest form, the respective Vice President shall consult with DSC Human Resources and/or DSC’s assigned legal affairs staff to assess the potential conflict of interest and ensure they are providing appropriate guidance and/or approval. The Vice President may consult with the President and/or Executive Cabinet as well for approvals presenting potential institution-wide impacts.

Outside activity approvers should provide a brief rationale for their approval / disapproval. Pursuant to delegated authority, the President can subsequently disapprove or approve. However, presidential review is optional, and the standard approval is at the vice-presidential level.

Exceptions & Special Considerations
  • Potential conflicts of interests involving the President are reviewed and approved by the Chancellor or the Chancellor’s designee.
  • All direct reports to the President and those with a title of Vice President or equivalent will have their conflict of interest disclosures reviewed by the University System Office before Presidential approval.
  • In instances involving a faculty member conflict of interest, either the faculty member, Dean, Provost, or President may request that the Faculty Senate Executive Committee refer the matter for review to a committee of faculty appointed by the executive committee or to a standing committee of the Senate. The Committee’s recommendations are advisory to the approval authority.
  • Please see the Conflict of Interest form.

2. Compensated Outside Employment

Requirements
  • Approval – Full-time employees5 must obtain written approval prior to the start of engaging in compensated outside employment (to include paid consulting, teaching, or speaking as well as participating in business, professional, or service enterprises) or other compensated activities that relate to the employee’s expertise or responsibilities as a DSC employee.
  • Prohibited Vendor Relationships – DSC employees are generally prohibited from consulting or otherwise receiving compensation from a current DSC vendor (or an entity seeking a vendor relationship with the College).9
  • Required Leave – Non-faculty employees and 12-month faculty employees must take appropriate leave if performing compensated outside activities during normal work time – please see the provisions below for additional detail on faculty consulting.
  • Annual Reporting Required – All DSC full-time employees shall submit an annual affirmation as to any compensated outside employment to include confirming that the employee is not participating in a compensated outside activity. This form normally will be due upon request or October 1 of each year.
  • Employee Guidance – If unsure as to whether or how this policy applies to a particular situation, DSC employees should consult with DSC Human Resources (HR).
  • Honoraria – Non-faculty employees may not receive Honoraria, as defined in Section 8.2.18.2.4 of BOR Policy, for activities during the employee’s work hours. Faculty members may receive standard Honoraria consistent with the definitions of BOR Policy 8.2.18.2.4. Approval for faculty honoraria is not required under this compensated outside activities policy.
Process
  • Employee: Any planned compensated outside employment should be discussed with the employee’s supervisor.
  • Employee: Employee should submit the Outside Activities form for approval by the respective Vice President (per delegated authority from the President).
  • Vice President (President): Before approving outside activities, the respective Vice President shall consult with DSC Fiscal Affairs to confirm there is not a current or potential vendor relationship, and check with the DSC Chief Human Resources Officer to review for any potential additional concerns. When reviewing for potential relationships, the Vice President should consider the impact of subcontractors and vendors who are performing work for a DSC primary contractor or vendor. The Vice President may consult with the President and/or Executive Cabinet as well for approvals presenting potential institution-wide impacts. Employees on a performance improvement plan must obtain presidential approval before participating in any new compensated outside activity.

Outside activity approvers should provide a brief rationale for their approval / disapproval. Pursuant to delegated authority, the President can subsequently disapprove or approve. However, presidential review is optional, and the standard approval is at the vice-presidential level.

Exceptions & Special Considerations
  • The President’s compensated outside employment is reviewed and approved by the Chancellor or the Chancellor’s designee.
  • All direct reports to the President and those with a title of Vice President or equivalent will have their compensated outside employment reviewed by the University System Office before Presidential approval. Please see the USG Human Resources Administrative Manual for links to the relevant forms for submittal.
  • Approval to conduct an outside activity does not constitute approval to use institutional resources to conduct an outside business or activity; use of institutional resources is prohibited in this instance.
  • Any request for an exemption to the policies in Board Policy 8.2.18.2 must be done in writing and submitted to the President. The President will review against the allowable exceptions and provide a formal written response to the employee within 14 business days. Please note that before any work can be done, the employee must receive a formal response granting approval from the President.
  • Faculty Consulting:
    • Introduction – DSC recognizes that teaching, research, and public service are the primary responsibilities of DSC faculty members. It is reasonable and desirable for faculty members to engage in additional activity beyond duties assigned by the institution, which are professional in nature and based in the appropriate discipline for which the individual receives additional compensation during the contract year.
    • Approval Required – All DSC faculty wishing to work in a consulting role outside of the institution must receive approval from the President before any such work may begin.
    • Process – DSC faculty should follow the same process as outlined under the compensated outside employment process with the caveat that the Provost will review and recommend approval or disapproval but the President will provide final approval. If approved, the faculty member will receive a written notice from the President stating the request has been approved.
    • Allowable Hours / Use of Leave – DSC faculty members who have received approval to engage in outside consulting during work hours may only do so for, on average, 1 day or 8 hours per week. Faculty members who are on a 12-month contract and earn annual leave must also take leave, consistent with USG and DSC procedures governing the use of leave, when engaged in consulting during their work hours, unless express permission is granted by the President.
    • Conflicts of Interest & Commitment – DSC faculty may be required to submit a conflict of interest / commitment form as determined by the Provost and/or President.
    • Use of Institutional Resources – DSC faculty desiring to use institutional resources must detail in writing their proposed use of DSC resources for approval; generally, incidental use of DSC resources may be permitted but more extensive use may require some form of reimbursement to the institution consistent with rates charged to outside groups or persons. Please see BOR Policy 8.2.18.2.4 for detailed information and definitions related to faculty consulting.
    • For additional information, please see BOR Policy 8.2.18.2 regarding outside activities that may create a conflict of interest. The policy can be found in the Board of Regents Policy Manual.
    • Please see the Outside Activities Form.

3. Conflicts of Commitment

Requirements
  • No Interference with DSC Duties – DSC employees shall not engage in any outside activity, to include both compensated outside activities and volunteer activities, that interferes with the regular and punctual discharge of the employee’s official duties.
Process
  • Employee: Employees are not expected to disclose every outside activity (unless otherwise required due to the compensated outside activity policy and/or conflict of interest policy); however, employees should avoid regular outside activities that prevent them from fulfilling their assigned duties and being present during their assigned work hours. In the event of a conflict, employees may take leave consistent with DSC policies on leave usage.
  • Supervisors: Supervisors are responsible for ensuring that assigned employees are fulfilling their DSC duties and present as required by the work assignment and DSC policies. Supervisors should engage with employees on an informal basis if they observe that outside activities are negatively impacting these employee expectations. If not resolved, supervisors must escalate the issue through the progressive discipline process.
Exceptions & Special Considerations
  • Military Duty – Employees may be engaged in military duty which is protected under Federal and State law as well as BOR policy and USG procedures. Military duty does not fall under the scope of these policies.
  • Professional Associations & Related Organizations – Various employees may engage in professional associations directly related to their DSC discipline as well as participate in community and related organizations in their capacity as DSC employees. For example, a faculty member may be part of a discipline-specific group while a CBO may be a member of NACUBO, or an internal auditor may be a member of ACUA, or a senior leader may be a member of the Chamber. In each instance, these engagements are generally considered within the scope of the employee’s duties and do not require approval as a compensated outside activity. However, employees must remain mindful of potential conflicts of interest arising from their membership and seek guidance consistent with the conflict of interest policy.
  • Leave – Occasional absences from work consistent with DSC leave policies are an acceptable way to manage conflicts of commitment. In fact, employees generally are expected to take leave if engaged in an outside activity during work hours. However, employees should be mindful that approving annual leave is within the discretion of the supervisor with respect to ensuring the efficient operation of a unit; as such, employees should not regularly take leave during assigned work hours as a means of managing a conflict of commitment.

4. Political Activities

DSC employees are encouraged to exercise their First Amendment rights, fulfill their civic obligations, and engage in the normal political processes of society. This includes the right to express their personal opinions on matters of public concern; to register to vote and otherwise participate in elections; and to participate in and make financial contributions to political organizations and campaigns. Nothing in this policy is intended to infringe or restrict free expression rights guaranteed by the United States Constitution or the Georgia Constitution.

Requirements
  • No Political Activities on Duty – DSC employees may not engage in political activities as outlined in the introduction while on duty to perform services for DSC, to utilize DSC or other public resources to do so, or to hold elective political office at the state or federal level while employed by DSC.
  • This policy shall not be construed to limit academic freedom as defined in DSC Policy and in Board Policy 6.5 Freedom of Expression and Academic Freedom.
  • Not Representing DSC – DSC employees must not hold themselves out as speaking or acting on behalf of DSC when participating in political activities and must take reasonable measures to avoid any appearance that such participation is in an official capacity as a DSC employee.
  • Please see Board Policy 8.2.18.3 related to political activities for further definitions and guidance.
Process
  • N/A
Exceptions & Special Considerations
  • N/A
Footnotes:
    1. A conflict of interest exists “when a reasonable person would conclude from the circumstances that the employee’s ability to protect the public interest, or perform public duties, is compromised by a personal, financial, or business interest” (definition from University System of Georgia (USG) Board of Regents (BOR) Policy 8.2.18.2.1).  See also state law, i.e., State Conflict of Interest Statutes O.C.G.A. § 45-10-20 through § 45-10-70.
    2. Compensated outside employment refers to both regular employment and one-time paid activities outside of the USG (dual appointments with another USG institution or the System Office are not considered outside employment) where the outside activity relates or is similar to their DSC job duties and responsibilities. For example, an accounting faculty member providing paid tax preparation activities at an accounting firm would be considered a related outside activity but not teaching a Yoga class at a local gym. A plant ops employee performing maintenance services for a local business would be considered a related outside activity but not serving as a part-time Uber driver.
    3. A conflict of commitment exists when an employee is engaged in any outside activity (compensated, volunteer, etc.) that interferes with the “regular and punctual discharge of that employee’s official duties.” (This policy is not meant to address military duty (multiple Federal, State, and BOR regulations govern this) nor does this policy address the various personal and familial activities during the work day for which an employee may use leave or other forms of authorized absence.)
    4. BOR Policy 8.2.18.2.1 related to research and institutional conflicts of interest.
    5. All DSC employees are subject to the conflict of interest requirements while full-time DSC employees (defined as a work commitment of 30 or more hours per week (.75 or >FTE) and faculty members on contracts of nine months or more) are subject to all three requirements (conflict of interest, compensated outside activities, and conflict of commitment).
    6. Employees should consult with HR, read the full text of the law, and consult with legal counsel as appropriate for a full and complete understanding of the legal requirements associated with the “for example” provisions.
    7. Disclosure currently is accomplished through the State Business Transaction Report due January 31 of each year. The DSC Office of Human Resources normally shall distribute information on this report each January.
    8. DSC employees also are subject to the provisions of Board Policy 8.2.18.4 governing the prohibited receipt of gifts for various reasons, from various entities, and in various forms.
    9. Exceptions to this prohibition may be granted by the College President for employees who do not supervise, regularly interact with, or participate in the selection of said vendor or potential vendor.