IS-2026 Conflict of Interest

Human Resources

Release Date: 11/2/2000
Revision 1: 11/07/2023

Introduction

To ensure that employees conduct themselves in a positive manner that promotes the best interests of Central New Mexico Community College (CNM), and to promote public confidence in the College, CNM enacts policies and procedures regarding conflict of interest in accordance with New Mexico State Statutes. 

Employees are solely responsible for and obliged under New Mexico State law to disclose and report activities that may present a conflict of interest or have the potential of putting themselves and/or the College as risk of violating State Statutes.

1. Conflict of Interest Activities

Activities which combine the personal and professional interests and the official acts and responsibilities of an employee are prohibited under this policy. Engaging in these activities will result in disciplinary action and/or legal action, up to and including termination. 

2. Disclosure

Any employee who knows of any act prohibited by law or by College policy or the code of conduct shall report it promptly to the appropriate administrator. 

2.1 Employees are required to disclose and disqualify themselves from participating in any official act directly affecting a business in which they and/or their immediate family have a financial interest. 

2.2 Employees are required to disclose any outside activities, relationships, or interests that would constitute a conflict of interest. 

2.2.1 This may include hiring and procurement activities. 

2.3 Disclosure should be made using the Conflict of Interest Disclosure Form to the Internal Audit Department. 

2.4 Failure to disclose conflict of interest activities may result in disciplinary and/or legal action, including possible termination. 

3. Reporting and Documentation

Employees have a legal obligation to report the activity of others believed to be conflict of interest activity. 

3.1 Report known, or suspected inappropriate activities to Internal Audit. 

3.2 Reporting should be documented using the Conflict of Interest Disclosure Form. 

3.3 Failure to follow up on known or suspected conflict of interest activities may result in disciplinary and/or legal action, including possible termination.

4. Action Plan

When a disclosed, known or suspected conflict of interest activity is reported, Internal Audit will determine if action is warranted based on documentation and investigation. 

4.1 Internal Audit will engage appropriate parties as necessary in the research process. 

4.2 Internal Audit will inform Human Resources and other appropriate departments of its findings. 

4.3 Human Resources will initiate disciplinary action if necessary. 

5. Definitions

Conflict of Interest

A conflict between the personal and professional interests and the official acts and responsibilities of an employee in a position of public trust. 

Immediate Family

The spouse, child or stepchild, grandchild, parent or stepparent, sister or stepsister, brother or stepbrother, grandparent, son-in-law or daughter-in-law or brother-in-law, mother-in-law or father-in-law or others who reside in the same household with the employee, or a person in loco parentis (a person who is acting in place of a parent or who is in the care of a person acting in place of a parent).


Human Resources

Release Date: 11/2/00

Procedure

1. Disclosing/Reporting a Conflict of Interest Activity

Employee (Self-disclosure) 

1.1 Disclose any outside activities, relationships, or interests that may constitute conflict of interest using the Conflict of Interest Disclosure Form

Employee (Witness) 

1.2 Report suspected, witnessed or known conflict of interest activity to Internal Audit using the Conflict of Interest Disclosure Form.

Internal Audit 

1.3 Discuss information with individual who completed disclosure form, if possible. 

1.4 Review available documentation and/or information to determine if action is warranted. 

1.4.1 If criminal violation is suspected, contact appropriate authority (CNM President, CNM Security, Legal counsel, outside law enforcement agency.) 

1.5 Contact Human Resources and other appropriate departments with findings of review. 

Human Resources 

1.6 Meet with employee to initiate action plan, including pre-disciplinary hearing if necessary. 


Forms:

Support Materials:

Not Applicable

Reference Materials: