Conflict of Interest Policy

I. PREAMBLE

Atlas University recognizes that trust is its greatest currency.
Every trustee, officer, faculty member, and employee serves as a steward of divine resources and must therefore act with undivided loyalty.
Conflict of interest—real or perceived—erodes integrity and endangers the sacred trust between the University and those it serves.

This Policy ensures that all members of Atlas University conduct themselves with transparency, fairness, and fidelity to the mission of Glorificatio Dei per Omnes Disciplinas.

II. PURPOSE

The purposes of this Policy are to:

  1. Identify and manage actual, potential, or perceived conflicts of interest.

  2. Protect the integrity and reputation of the University.

  3. Ensure compliance with federal and state nonprofit laws.

  4. Affirm the biblical and ethical foundation of selfless stewardship.

III. SCOPE

This Policy applies to:

  • All members of the Board of Trustees.

  • All officers, administrators, faculty, and employees of Atlas University.

  • Any contractor, consultant, or volunteer with fiduciary or decision-making authority.

IV. DEFINITIONS

  1. Conflict of Interest — A situation in which a person’s personal, financial, or familial interests could compromise, or appear to compromise, their professional judgment or duty to the University.

  2. Interested Person — Any individual who has a direct or indirect financial interest in a transaction or arrangement involving the University.

  3. Financial Interest — Ownership, investment, or compensation arrangement that may benefit an individual through business dealings with the University.

  4. Fiduciary Duty — The obligation of loyalty, prudence, and good faith owed by trustees and officers to the University.

V. GENERAL POLICY

All trustees, officers, and employees must:

  1. Place the interests of the University above personal or private interests.

  2. Avoid participation in decisions where personal gain may be derived.

  3. Disclose any potential or actual conflicts immediately upon awareness.

  4. Act with complete honesty, fairness, and transparency in all dealings.

VI. DISCLOSURE REQUIREMENTS

1. Annual Disclosure

Each trustee, officer, and key employee must complete the Conflict of Interest Disclosure Form (Form COI-01)annually, declaring any financial, familial, or organizational affiliations that could present a conflict.

2. Transactional Disclosure

If a conflict arises during the year, the individual must disclose it promptly to:

  • The President (for faculty and staff);

  • The Board Chair (for officers); or

  • The Governance and Ethics Committee (for trustees).

3. Recording

All disclosures shall be recorded in the minutes of the relevant meeting and kept on file by the Office of the General Counsel for at least seven (VII) years.

VII. REVIEW AND RESOLUTION PROCEDURES

  1. Determination of Conflict — Upon disclosure, the disinterested members of the reviewing body (Board or Committee) shall determine whether a conflict exists.

  2. Recusal — Any person with a potential conflict shall abstain from discussion, decision, or vote related to the matter.

  3. Independent Evaluation — When appropriate, the University shall seek competitive bids or independent counsel to ensure fairness.

  4. Approval — The transaction may proceed only if determined to be in the best interest of the University and not excessive in cost or contrary to its mission.

  5. Documentation — All deliberations and decisions must be recorded in official minutes.

VIII. PROHIBITED CONDUCT

  1. Self-Dealing — Engaging in transactions for personal benefit or that disadvantage the University.

  2. Private Inurement — Using University assets for personal enrichment or non-University purposes.

  3. Gifts and Gratuities — Accepting monetary gifts, favors, or services that may influence decision-making, except nominal items (value under $50).

  4. Use of Confidential Information — Using privileged information obtained through one’s position for personal or third-party gain.

IX. VIOLATIONS OF POLICY

  1. Failure to Disclose — May result in disciplinary action, up to removal from position or termination.

  2. Investigation — Conducted by the Governance and Ethics Committee or, when appropriate, by independent counsel.

  3. Sanctions — Determined by the Board or President based on the severity of violation.

X. TRAINING AND ACKNOWLEDGMENT

  1. All trustees and employees shall receive orientation and periodic training on fiduciary ethics, financial transparency, and conflict-management principles.

  2. Each individual must sign an acknowledgment of understanding and compliance annually.

XI. RECORDKEEPING

The Office of General Counsel shall maintain all disclosure forms, committee minutes, and resolution records for a minimum of seven (VII) years in accordance with the Records Management and Legal Compliance Policy.

XII. ETHICAL AND SPIRITUAL FOUNDATION

Atlas University teaches that integrity is indivisible.
Fiduciary purity mirrors the priestly call to holiness—serving not one’s own gain, but the glory of God through faithful stewardship.
As it is written: “It is required in stewards, that a man be found faithful.” (I Corinthians 4:2)

XIII. REVIEW AND AMENDMENT

This Policy shall be reviewed annually by the Governance and Ethics Committee, approved by the President, and ratified by the Board of Trustees.