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
- 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.
- 2018-2019 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 (Rev. 1/2017) – 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.
- 2018-2019 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 (Rev. 4/2017) – 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.
- 2018-2019 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.
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.
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).
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.