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Conflict of Interest


General Prohibition
Under the Political Reform Act of 1974 (Government Code Sec. 81000 et seq.), no CSU employee shall make, participate in making, or attempt to use his or her official position to influence a CSU decision in which he or she has a financial interest. Willful violation is a misdemeanor.

An employee has a personal financial interest in a decision if the decision will have a material financial effect on the employee, a member of his or her immediate family, or on any one of the five kinds of economic interests (.doc, II,A,2b).

The Fair Political Practices Commission (FPPC), the agency assigned to administer and interpret the Political Reform Act, has provided an eight-step analysis (.doc, II,A,3) to determine when an employee has a conflict of interest that would require the employee to disqualify him or herself from the decision-making process.

FPPC Form 700
In addition to the above requirements that apply to all CSU employees, the CSU Conflict of Interest Code applies to specifically designated CSU employees who are considered most likely to make, participate in making, or influence decisions that could significantly affect personal economic interests.

Employees are required to file a public document, FPPC Form 700 (.pdf), with the campus filing officer when they first occupy a designated position, annually thereafter by April 1, and at the time the employee leaves the designated position. The law provides for a $10 per day fine for each day the Form 700 is late beyond April 1.

Rules on Gifts and Honoraria
The CSU Code also prohibits receipt of honoraria (.doc, II,B,5a) in any amount and gifts (.doc, II,B,5b) over a set amount. The rules are summarized in a fact sheet (.pdf).

Contracts with the CSU/Independent Contractors
The Public Contract Code contains four rules (.doc, III,B) that apply to employees and former employees regarding contracts with the CSU. For more information see: Using Confidential Information
It is unlawful under Education Code Sec. 89006 to utilize nonpublic information received by reason of CSU employment or a CSU contract for personal pecuniary gain.

Gifts of Public Funds/Using State Resources for Nonstate Purposes
Gifts of public funds (.doc, V,B) are prohibited, as is using state resources (time, facilities, equipment or supplies) for nonstate purposes.

Salary as Compensation in Full
The law forbids payment of extra compensation or bonuses (.doc, V,C) to a public employee after service has been rendered.

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Last Updated: March 5, 2007