Conflict of Interest
Conflict of Interest Prevention
The CSU has moved to an online Form 700 submission system.
What is Conflict of Interest?
Conflict of interest occurs when professional duties and personal interests intersect, putting a person in a position to personally benefit from a decision made as part of his or her job duties. As public employees, California State University (CSU) employees are subject to various conflict-of-interest-related laws and regulations.
The primary California legislative document governing conflicts of interest is the Political Reform Act of 1974 (the Act), which prohibits public employees from making, participating in making, or in any way attempting to use their official position to influence a governmental decision in which they know, or have reason to know, they have a financial interest. This applies to all CSU employees. Primary responsibility is placed upon the individual employee to be familiar with the requirements of the Act. In addition, if CSU employees have a personal financial interest in a university decision, they are required to publicly announce the financial interest and disqualify themselves from involvement in the decision. CSU employees should also be sensitive to the appearance of conflict of interest when participating in university decisions, even when a true conflict does not exist.
Annual Filing Reminder
The campus COI Filing Officer should distribute Statement of Economic Interests (Form 700) to employees in designated positions, as well as those identified through the interim disclosure process, as soon as possible. Designated employees must submit completed forms to the campus Filing Officer by April 3rd, 2023.
Annual Filing Documents
- CSU Disclosure Category Listing - This updated list contains eight (8) disclosure categories.
- Campus Designated Position List - Identifies the designated positions submitted during the remapping process and
approved by the FPPC, effective January 1, 2017.
- 2020-2021 Statement of Economic Interests Form 700 - (schedules and instructions). Filing Officers are required to review completed statements
of economic interests ensuring that a completed individual disclosure statement is
received, and that the date is indicated in the official date stamp box located in
the upper right hand corner of Form 700. Copies of Form 700 can be reproduced locally
for appropriate employees at your campus. Form 700 also can be accessed electronically
via the internet at: http://www.fppc.ca.gov.
- Frequently Asked Questions: Form 700 Disclosure – Provides a list of frequently asked questions that are often asked to FPPC by employees
completing Form 700. Frequently asked questions regarding gift disclosure are also
included.
- 2020-2021 Form 700 Statement of Economic Interests Reference Pamphlet – Provides information to assist employees in designated positions on how to complete
their Form 700.
- Limitations and Restrictions on Gifts, Honoraria, Travel and Loans Fact Sheet – This fact sheet summarizes the major provisions concerning gifts, honoraria, travel
and loans. The aggregate limitation on gifts, which is indexed for inflation every
two years, is $500 (2018-2019 limit) from a single source in a calendar year.
- 2022-2023 Principal Investigator's Statement of Economic Interests Form 700-U and
Instructions for Statement of Economic Interests for Principal Investigator – Form 700-U should be made available to employees "with principal responsibility
for a research project funded or supported, in whole or in part, by the contract or
grant (or other funds earmarked by the donor for a specific research project, or for
a specific researcher) from a non-governmental entity."
- Conflict of Interest Handbook – This handbook prepared by the Office of General Counsel provides information on conflict statutes.
Principal Investigators
There is no "annual" filing requirement for Principal Investigators (PIs); however, Title 2 regulations require PIs to file a form 700-U (Statement of Economic Interests for Principal Investigators) before the final acceptance of a contract, grant or gift for a research project from a non-governmental entity, and within 30 days of renewal of funding for such a contract or grant.
Principal Investigators must complete the ethics training within six (6) months of receiving the grant. Subsequent training is required at least once within each two calendar year period that the grant is in place.
Ethics Training
California State law mandates that employees who must file a Statement of Economic Interest Form (FPPC Form 700), or designated employees, must take an ethics training every two years or within six months of first assuming their designated position. Employees in Designated Positions are likely to encounter decisions where a conflict of interest might arise. The CSU further designates its employees must take a CSU-specific Conflicts of Interest trainings.
Enforcement Considerations
Employees are subject to a $10 per day fine up to a maximum of $100 for the late filing of a Statement of Economic Interests Form 700 (Government Code Section 91013). In addition, the President/Chancellor may be notified of the late filers.
Employees who fail to file a Form 700, or who fail to disclose material interests may be subject to a personal penalty. Penalties include disciplinary action against the employee, as well as potential civil and criminal penalties. Violations of the Conflict of Interest Code are addressed in the Conflict of Interest Handbook, prepared by Office of General Counsel.
Filing Procedures
Newly Appointed: Employees appointed into a designated position must file a Statement of Economic Interests Form 700 within 30 days of the appointment date, as well as take an online Ethics/COI Training course within 6 months of their appointment date and every two years thereafter. This is web based training and may be taken from any computer with Internet access.
Annual Filing: Employees in a designated position must file an annual Statement of Economic Interests Form 700 by approximately April 3rd of each year.
Leaving Office: When an employee leaves their designated position they must file a Statement of Economic Interests Form 700 within 30 days of leaving office.
For Assistance, please contact:
Elba Cruz
COI Filing Officer
(707) 654-11419
ecruz@csum.edu
Michael J. Martin
AVP, HRSRM Diversity & Inclusion
(707) 654-1135
mmartin@csum.edu
Fair Political Practices Commission (FPPC)
Toll-Free: 1-866-ASK-FPPC (1-866-275-3772)
http://www.fppc.ca.gov/