Compliance Compass

Updates from the Office of Compliance, Risk, and Ethics
December 2024

A picture of several, colorful Christmas presents and the words “appearance counts.”

Three Ways to Avoid Conflicts of Interest During the Holidays

Holidays are almost here! ‘Tis the season to enjoy family, food, music, and gifts. But it is the last item in the list that can cause problems for employees who are not familiar with the College’s Policy and Procedure 31003—Conflict of Interest. Let’s remember that a conflict of interest is defined as “any situation in which a member of the College community has an interest or loyalty that directly or indirectly affects, or has the appearance of affecting, the individual’s professional judgment in performing any College duty or responsibility.” Here are some basic rules to avoid conflicts of interest regarding gifts during the upcoming holiday season.

1. Gift Baskets from Vendors.
While the College’s current Conflict of Interest Disclosure Policy and Procedure 31003 does not explicitly address gifts from vendors, updates are being considered that will expand the gift section and provide clearer guidance. In the meantime, employees should exercise sound judgment and avoid accepting gifts that could impair one’s independent judgment. For example, gift baskets given by an existing or prospective vendor can be shared with one’s team or placed in a common area of the office. Sharing the gift transforms it from a personal benefit into one that serves a broader purpose, minimizing concerns about impartiality.

2. Exchanging Gifts Among Colleagues.
It’s fine to exchange gifts, such as gift cards, among colleagues, provided personal funds are used. However, please remember that College operating funds may not be used to purchase gift cards for College employees. Please see the College’s Policy and Procedure 63001—Procurement, Contracts, and Consultant Services (Section II.D.) as a reference.

3. Gifts to Students.
When providing gifts to students, please keep in mind the College’s Policy and Procedure 63001—Procurement, Contracts, and Consultant Services. Section II.D. prohibits student gift card purchases unless prior documented approval is obtained from the Senior Vice President of Administrative and Fiscal Affairs with the advice of the Director of Procurement. Faculty and staff are encouraged to explore alternative ways to recognize and support students while adhering to College guidelines.

A conflict of interest can compromise the College’s reputation, culture of integrity, financial resources, and the public trust. It doesn’t matter whether that conflict is intentional or an oversight. “When in doubt, tell the truth”—by Mark Twain. If you have questions about whether a gift is appropriate, please contact the Office of Compliance, Risk, and Ethics. All employees need to be as transparent as possible.

Need to Disclose a Conflict of Interest?

A picture of a group of coworkers around a table with someone holding a gift basket. It reads “When vendor gifts come your way share with your team so save the day! You must share gift baskets from vendors with your team or leave it in a common area of the office. No need to complete a Conflict of Interest Disclosure Form.”

More Situations and Solutions

Many of you reached out to our office to let us know how much you enjoyed our Compliance and Ethics Awareness Week’s “situations and solutions” series. Because of the positive feedback, we are including more in our quarterly newsletters. We hope these situations, or scenarios, get employees thinking and talking.

1. I regularly joke with an older employee about his inability to keep up because he's too old. Could this be considered harassment even though I'm only kidding?

Yes. He may not tell you he's offended, but he may tell a supervisor or just keep it to himself. Regardless of his actions, you should show respect for the person and not joke about any individual's protected status. You should not assume he is not offended by your comments just because he doesn't say anything. Remember, respect is one of the expectations listed in the College P&P 31000—Code of Ethics and Employee Conduct.

2. A coworker comes to you and confides that they have been experiencing harassment at work. They ask you to keep it a secret because they are afraid of retaliation. What should you do?

If you are not your coworker’s supervisor, you may respect your coworker’s wishes and keep the matter between the two of you. However, you should encourage your coworker to report the harassment directly to EELR or through EthicsPoint, the College’s hotline, which allows for anonymous reporting. Likewise, if you are concerned on your coworker’s behalf, you also may make a report through EthicsPoint about what they told you.

Even if you or your coworker identifies yourselves in the report, OCRE and EELR will maintain confidentiality to the full extent feasible and disclose a reporter’s identity only on a need-to-know basis. Please be assured that all employees who make reports in good faith are protected from retaliation by College P&P 39003—Protection Against Retaliation, and OCRE takes this mandate seriously.

Annual Security Report

The College's Annual Security Report (Clery Act) is available. It contains information and crime statistics of the College, as well as relevant programs and policies that keep the MC community safe. Download your copy of the Annual Security Report here.

if you wish to have a hard copy of the report, please contact the Office of Public Safety, Health, and Emergency Management at 240-567-2033.

And the Winner is...

Congratulations to Lisa Evans, winner of our Compliance and Ethics Awareness Week drawing! A hearty "Thank You" to all who submitted their answers and engaged in our daily challenges. We hope you enjoyed them, as well as the workshops and the situations and solutions. Please offer your ideas or suggestions to enhance next year's Compliance and Ethics Awareness Week.

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