Outside Employment Reporting Guidelines

  1. Purpose:

    The following guidelines provide additional procedural details and support related to reporting of secondary employment outside of the University.

  2. Scope

    These Guidelines apply to all Regular Staff employees.

  3. Guidelines

    1. All Regular Staff employees are required to report secondary employment outside of the University in accordance with University Policy.

      1. Best efforts should be made to timely report outside employment/commitments and to update the University as to any changes which may affect a staff member’s primary role.

      2. Reminder notifications will be sent periodically directing employees to report any outside employment secured in the previous year.

      3. Timing of reporting should typically occur as follows:
        1. Current employees should report new outside employment prior to commencing any outside work/activities.
        2. New hires should report existing outside employment during onboarding, or otherwise as soon as possible upon commencing employment with the University.

      4. To submit forms or other documentation electronically employees should utilize .

    2. Generally, outside employment or other commitments which may require reporting are as follows:

      1. Mandatory reporting — Any regular, paid outside employment or service on official boards or commissions; such employment / commitments require reporting to the State Ethics Commission and assessment / clearance regarding conflict of interest.
      2. Permissive/Potential reporting — Unpaid, volunteer, or alternative compensation arrangements which represent a reasonably significant time commitment and/or potential conflict.
      3. Reporting not required — Minimal commitment volunteer or other unpaid engagements with limited to no nexus to the employee’s position or the University.
    3. Mandatory Reporting
      1. For those outside positions/commitments which are mandatory subjects of reporting, the State Ethics reporting form (Form 25) must be completed and returned to the Office of Human Resources (“OHR”).

      2. The State Ethics Commission will conduct its assessment and return the results to the OHR. Should no conflict of interest be identified, the employee will be notified and the Form 25 will be confidentially recorded by the OHR.

        1. If no conflict per State Ethics regulations exists, employees remain subject to the conflict of commitment provisions of the Policy and are obligated to maintain satisfactory performance of the primary role.

      3. In the event of an identified conflict of interest, the employee will be required to discontinue the outside employment/commitment in a timely manner. Proof of severance of the employment / commitment in conflict is required and should be submitted promptly to the OHR.

    4. Permissive / Potential Reporting

      1. Outside employment/commitments which are not subject to mandatory State ethics reporting, but may otherwise require reporting, should be submitted to the OHR via the internal assessment form. Reporting should occur prior to commencing the commitment if possible, but in any event as soon as is practicable.

      2. Upon receipt of the internal form, the OHR will assess and follow up with the employee as needed.

      3. If determined that reporting is required, the employee will submit Form 25 to receive a decision regarding conflict of interest and further guidance as to potential conflict of commitment.

      4. If determined that reporting is not required, the internal reporting form will be retained by the OHR for future reference and/or consultation if needed. The employee must manage the commitment appropriately so as not to disrupt performance of their primary role.

        1. OHR reserves the discretion to disclose a non-reportable outside role to the employee’s department in the event it becomes reasonably necessary for administrative or employment purposes (e.g. performance management or investigative reasons).

      5. If unsure whether an outside role or commitment is reportable, the employee should submit a request for review via the internal assessment form.

    5. No Reporting Required

      1. Unpaid/volunteer commitments representing minimal time or impact on the primary role need not be reported.

      2. If in doubt as to whether such a commitment should be reported, the employee should consult their assigned HR Partner.

    6. Compliance and Enforcement

      1. Employees must comply with the Policy as implemented by these reporting guidelines. Failure to comply may be subject to corrective or disciplinary action depending on the circumstances.

      2. Should outside employment/commitment disrupt operations or otherwise adversely affect job performance, the department reserves the right to address administratively as it would in any situation involving poor job performance.

      3. The OHR should be consulted in instances of potential noncompliance prior to action being taken.

Related Policies, Documents and SOPs: