For Trustees, Officers, and Employees
(Adopted Originally by Trustees April 15, 1978)

It is the responsibility of the trustees, officers and employees of Colby College to administer the affairs of the College honestly and economically, exercising their best care, skills and judgment for the benefit of the College.

I. Therefore, it is the policy of the Board and the College that:

A. The trustees, officers and employees of Colby College shall exercise the utmost good faith in all transactions touching upon their duties to the College and its property. In their dealings with and on behalf of the College, they shall be held to a strict rule of honest and fair dealings between themselves and the College. They shall not use their positions or knowledge gained therefrom in such a way that a conflict might arise between the interest of the College and that of the individual.
B. All acts of such persons shall be for the best interest of the College.
C. Such persons shall not accept any gifts, favors, or hospitality that might influence their decisions or actions affecting the College.
D. Although it is recognized that a degree of the duality of interest may exist from time to time, such duality shall not be permitted to influence adversely the decision making process of the College. To this end, in the event any person subject to this policy shall be called upon to consider a transaction involving 1) the College and such individual or a member of his or her immediate family, or 2) the College and an organization with which such individual is "affiliated," that individual shall make a full disclosure of all facts concerning his or her interest or involvement in such transaction and/or such organization before that transaction is consummated. Such individual shall also refrain from participation in the College's consideration of the proposed transaction.

II. The following persons shall complete and sign a certificate of compliance in which they disclose all their relationships and business affiliations that reasonably could give rise to a conflict of interest involving the College:
A. Trustees (including the President) shall complete a certificate annually; and
B. College officers, all other administrative staff members and faculty members having administrative responsibilities (including department heads) shall complete a certificate every third year. In addition, each trustee, college officer, administrative staff member or faculty member having administrative responsibility shall notify the appropriate official (specified in the final paragraph of this document) immediately if any such conflict, real or potential, should arise while said person is affiliated with the College.

III. The President may also require disclosure from time to time from any other employee or faculty members when, in the opinion of the President, and by virtue of such persons' respective duties and responsibilities, the College should receive a continuing disclosure of such outside relationships and business affiliations.

For purposes of this policy, the individual is affiliated with an organization if he or she or a member of his or her immediate family (i.e. his or her spouse, and their parents, children, brothers and sisters).
A. Is an officer, director, trustee, partner, employee or agent of such organization; or
B. is either the actual or beneficial owner of more than one percent (1%) of the voting stock or control interest of such organization; or
C. has any other direct or indirect dealings with such organization from which he or she knowingly is materially benefited. For purposes of this subparagraph, it shall be presumed that a person is "materially benefited" if he or she received directly or indirectly cash or other property (exclusive of dividends and interest) in excess of $100 in any year in the aggregate.

All disclosures required to be made under this Policy by any person other that the College President, Vice Presidents and Trustees shall be directed in writing to the President. Disclosure of the President, Vice Presidents and Trustees shall be directed in writing to the Chairman of the Board. All known violations, disputes and other issues arising out of the application of this Policy to all officers and employees (exclusive of the President, Vice Presidents and Trustees) shall be referred to the President for appropriate action.