Williams College Employee Handbook
Conflict of Interest
Annual Conflict of Interest Disclosure Form
The following information is presented in compliance with the Code of Conduct approved by the Board of Trustees. This Disclosure Form is to be completed and filed annually with the Office of the Vice President for Finance & Administration by members of the President's Administrative Group ("PAG"), with the exception of Officers and members of the Senior Staff (who instead comply with the more extensive Policy on Conflicts of Interest for Trustees and Officers), and by designated other members of the administrative staff whose positions, job responsibilities or relationships could give rise to conflicts of interest. This Disclosure Form is to be completed and filed with the Office of the Dean of the Faculty by designated members of the faculty whose job responsibilities or relationships could give rise to conflicts of interest.
I. Being a member of the faculty or of the staff of Williams College, I hereby state that to the best of my knowledge, except as noted below:
- I do not now, and during the College's 2016 fiscal year did not at any time, have an "official relationship" with any entity that transacts business with the College;
- I do not now, and during the College's 2016 fiscal year did not at any time, transact any business with the College for which I receive or received remuneration (except for compensation paid with respect to employment with the College);
- No member of my family (spouse, ancestors, children, grandchildren, siblings or the spouses of children, grandchildren, or siblings): has now, or at any time during the College's 2016 fiscal year had, an "official relationship" with any entity that transacts business with the College; or transacts currently, or at any time during the College's 2016 fiscal year transacted, business with the College for which s/he receives or received remuneration (except for compensation paid with respect to employment with the College).
Exceptions to the above statements:
II. I am now, or was at some time during the College's 2016 fiscal year, a trustee, director or officer of the following for-profit and not-for-profit organizations:
III. I agree that if circumstances change or information comes to my attention such that the foregoing information is no longer accurate, I will promptly file an amended disclosure form with the Office of the Vice President for Finance & Administration and Treasurer or the Office of the Dean of the Faculty, as appropriate. I understand that all such information may be disclosed by the College to the extent it is required to do so in order to comply with Federal and state tax return disclosures or other governmental requirements and that otherwise such information will be held in confidence unless the best interests of the College dictate otherwise.
Please return to the Office of the Vice President for Finance & Administration or the Office of the Dean of the Faculty.
Examples of conflicts of interest disclosed under the Conflict of Interest Policy
I. Conflict of Interest due to Vendor relationship:
- Employee or family member (spouse/partner, sibling, parent, child) owns a company or runs a business that sells goods or services to the College, for example, food, office supplies, professional or construction services.
- Employee's family member is a self-employed contractor who does work for the College. This does not include the case of the employee's family member employed by a firm he/she does not own unless the College employee is in a position to direct the work given or evaluate the services of the firm.
II. Conflict of Interest due to Financial relationship:
- Employee or family member is an investor, officer, or board member of a for-profit company that does or seeks to do business with the College, for example, banks, professional service firm, construction contractor, or information technology consultant.
III. Conflict of Interest due to governance relationship:
- Employee is a non-paid member of a non-profit governing board, i.e., hospital, museum, youth organization, religious institution that contracts with or receive money or other support from the College.
- Employee is a member of a town or regional governmental agency that has regulatory authority over some aspect of the College's operations.
Updated November 24, 2014