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Conflict of Interest Disclosure Procedures

TBR Policy Reference: 1:08:01:00

Approved by: President's Cabinet

Original Date Effective: 2013-10-09

Last Modified: 2021-12-13


Conflict of Interest – Occurs when the personal interests, financial or otherwise, of a person who owes a duty to the Tennessee Board of Regents and its constituent institutions (Regents and all employees) actually or potentially diverge with the person’s professional obligations to and in the best interest of the TBR and its institutions. 

In order to ensure that no conflict of interest occurs, the following institutional procedure has been created: 

  1. General Disclosure – Persons who believe a conflict of interest may exist either personally or with respect to another person covered by TBR policy shall make a written disclosure of the facts and circumstances surrounding the situation. No particular format is required, but the disclosure should adequately describe the pertinent facts and circumstances. Disclosures are submitted to the President’s Office for review by the Conflict of Interest Disclosure Review Committee. 
  2. Grant Investigator – Investigator is defined as the principal investigator, co-principal investigators, and any other person responsible for the design, conduct, or reporting or research or educational activities funded or proposed for funding. 

    Investigators seeking funding from federal, state and/or local grants are required to disclose all significant financial interests: 1.) that would reasonably appear to be effected by the scope of the grant; 2.) in entities whose financial interests would reasonably appear to be affected by such activities. Such disclosures must be submitted prior to the time the proposal is submitted to the funding agency. Further, such disclosures must be updated during the period of the award; either annually or as new reportable financial interests arise. To facilitate such disclosures, the Jackson State Community College Disclosure of Interest Form (Attachment A) will be used for local, state and federal grants. Investigator’s seeking funding from federal grants from the Public Health Services (including the National Institutes of Health) or the National Science Foundation, must also complete the Jackson State Community College Disclosure of Interest for Federal Grants. 

    Disclosures are submitted to the President’s Office for review by the Conflict of Interest Disclosure Review Committee. Disclosure of financial interests made pursuant to this special disclosure requirement, does not eliminate the responsibility for making disclosures under general disclosures, when specific conflict of interest situations arise.

  3. President – The President is required to annually file an online Statement of Disclosure of Interests Form with the Tennessee Ethics Commission (Form SS-8005). Along with review by the Tennessee Ethics Commission, a copy is forwarded to the Tennessee Board of Regents, Office of General Counsel. 
  4. JSCC Administration – The Vice Presidents, Deans, Business Services Director, Director of Workforce, Small Business Development Director, and Director of Purchasing are required to file a Jackson State Community College Statement of Disclosure Form within one month of their initial appointment and annually thereafter in January. Disclosures are submitted to the President’s Office for review by the Conflict of Interest Disclosure Review Committee. 

  5. Athletic Department – Coaches, assistance coaches, and exempt employees of the athletic department are required to complete the Tennessee Ethics Commission’s Statement of Disclosure Form (Form SS-8008) within one month of their initial appointment and annually thereafter in January. Disclosures are submitted to the President’s Office for review by the Conflict of Interest Disclosure Review Committee. 

All original Statement of Disclosures will be kept in personnel files with copies to the President’s Office and the Director of Purchasing for review to assure compliance with purchasing and contracting policies. 

Attachments

  1. Conflict of Interest Disclosure Form
  2. Disclosure of Interest for Federal Grants