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Conflict of Interest

The Political Reform Act, Government Code Sections 81000, et seq., requires California State University (CSU), as an agency, to adopt and promulgate COI codes. The CSU's COI code requires employees in designated positions, including those identified under the interim disclosure process to file a Statement of Economic Interests (Form 700) on an annual basis. In addition, select consultants hired through the procurement process are also required to file a Statement of Economic Interests (Form 700) on an annual basis. 

CSU Conflict of Interest Code

The Fair Political Practices Commission (FPPC) approved CSU's COI Code effective January 1, 2017. The new COI Code which consists of an updated list of designated positions and disclosure categories applies to this year's COI annual filing.
 

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, and no later than March 1, 2019, - 30 days before the filing is due. Designated employees must submit completed forms to the campus Filing Officer by April 2, 2019.

Annual Filing Documents

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

All employees in designated positions, including those that fall under the interim disclosure requirement and select principal investigators and consultants, must complete the ethics training. The training is delivered online and is accessible wherever web access is available. It is delivered in an interactive format. Completion time is approximately 45 minutes, with testing embedded throughout content. A unique course link will be sent to each participant by our learning management system (LMS).

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.
 
 
 

 

 
 

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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 1st 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: 
Barbara Reece
COI Filing Coordinator
(707) 654-1021
 
Ingrid Williams
AVP of Human Resources, Diversity & Inclusion, and Administration
(707) 654-1135

Fair Political Practices Commission (FPPC)
Toll-Free: 1-866-ASK-FPPC (1-866-275-3772)
http://www.fppc.ca.gov/

 
 

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