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Conflict of Interest

The Political Reform Act of 1974, Government 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.

The Political Reform Act of 1974 contains a general prohibition against conflicts of interest in public decision making, as well as a provision for the adoption of a CSU conflict of interest code. It prevails over any other conflict of interest law. (Gov’t Code § 81013) The restrictions of this Act apply to all CSU employees, without regard to whether they are required to file an annual conflict of interest form. 

“No public employee at any level of state or local government shall make, participate in making, or in any way attempt to use his [or her] official position to influence a governmental [CSU] decision in which [s/he] knows or has reason to know [s/he] has a financial interest.” (Gov’t Code § 87100)

Any person who willfully violates the general prohibition is guilty of a misdemeanor. (Gov’t Code § 91000) This prohibition applies to all CSU employees. 
 

Filing

The CSU Conflict of Interest code requires all CSU employees in a designated position and interim disclosure positions to file a Statements of Economic Interests (Form 700) on an annual basis and take the CSU's Avoiding Conflict of Interest Training within 6 months of assuming office, and then every two years after.

Designated employees are provided notification of their disclosure status and filing requirement via email.

Assuming Office: CSU employees assuming office in a designated position must file a Form 700 within 30 days of their appointment.

Annual Filing: CSU employees in designated positions are required to file a Form 700 by April of each year. The University's Conflict of Interest Filing Officer is responsible for notifying employees who must file.

Leaving Office: CSU employees in designated positions with the University are required to complete Form 700 within 30 days of leaving office.

Training

All employees in designated positions must complete the CSU's Avoiding Conflicts of Interest training course within 6 months of assuming office and every 2 years thereafter. The training is delivered online and in an interactive format accessible through CSU Learn. Employees required to complete ethics training will be sent an email notification from hr@csusm.edu. If you believe you are in a designated position and have not received notification, please contact HR.

Gifts to Agency/Distribution of Tickets and Passes to Events/Report of Ceremonial Roles

In addition to the administration of the annual filing of Statement of Economic Interests forms for designated positions, the University is required to report Gifts and Tickets/Admissions to Events given to the agency.

Payments made to the CSU by an outside source that are used by CSU employees to conduct CSU business or to achieve a stated public purpose may not be treated as gifts or income by the employee who uses them. These payments may be reported on a Form 801 or Form 802 instead of the employee's Form 700.

Gifts to Agency Report

The Form 801 is used to disclose gifts made to the CSU and used by one or more CSU employee to conduct CSU business. This may include payments such as travel and reimbursements (other than tickets or passes). View CSUSM completed Form 801.

Ceremonial Role Events and Ticket/Pass Distributions Agency Report

The Form 802 is used to disclose tickets or passes to an entertaining or sporting event given to the CSU by an outside source and provided to a CSU employee to achieve a stated public purpose. View CSUSM completed 802.