It is the policy of the Research Foundation (hereinafter referred to as "the Foundation") that its staff (hereinafter referred to as "RF employees") perform their duties in an ethical manner that will ensure no conflict, nor any appearance of a conflict of interest, between their personal interests and those of the Foundation. A conflict of interest exists when individual commitment to the Foundation may be compromised by personal benefit. RF employees are expected to avoid situations or activities that could interfere with their unencumbered exercise of judgment in the best interests of the Foundation.

Since it is impossible to describe all of the situations that may be, or give the appearance of, unethical behavior or a conflict of interest, the prohibitions included in this policy are not intended to be exhaustive and include only some of the more clear-cut examples.


RF employees are expected to represent the Foundation in a positive and ethical manner. Thus, they have an obligation to avoid unethical behavior and to refer all questions and concerns to the President or his/her designee.

When a relative or partner of an RF employee is being considered for employment with the Foundation, the RF employee must disclose the relationship to the President or his/her designee. RF employees must disclose any financial interest they or their immediate family have in any entity that conducts business with the Foundation to the President or his/her designee. The Foundation may require divestiture of the interest if it considers the financial interest to be in conflict with its best interest. The Foundation may also prohibit an RF employee from exercising decision-making authority or exerting influence concerning any entity or transaction in which they or a family member have a personal interest.

Employees, their co-workers, or their supervisors must disclose any unethical behavior, conflict, or potential conflict of interest, to the President or his/her designee. Failure to do so on the part of any employee will result in disciplinary action, up to and including termination of employment. In addition, disciplinary measures, up to and including termination of employment, will be taken against any RF employee who directs or approves infractions or has knowledge of them and does not promptly report and correct them. To encourage the full disclosure of potential conflicts, disclosures are treated confidentially.

What RF employees MAY NOT do:

  • RF employees may not engage in, directly or indirectly either on or off the job, any conduct which is disloyal, disruptive, competitive, or damaging to the Foundation.
  • RF employees may not accept any simultaneous employment relationship with any entity that does business with, or seeks to do business with, or competes with the Foundation.
  • This prohibition on employment includes serving as an advisor or consultant to any such entity, unless the activity is conducted as a representative of the Foundation.
  • RF employees may not participate in a joint venture, partnership, or other business arrangement with entities or individuals that do business with, seek to do business with, or compete with the Foundation.
  • RF employees and their immediate families may not accept free or discounted goods or services of any kind nor may they purchase goods or services of any kind from any entity or individual doing business with the Foundation that would generally be difficult or impossible for an RF employee to obtain on his or her own or that would not otherwise be available to the general public.
  • RF employees may not give, offer, or promise, directly or indirectly, anything of value to any representative of a customer, or a potential customer, or of a financial institution in connection with any transaction or business that the Foundation may have with that customer, potential customer, or financial institution.
  • RF employees may not accept, agree to accept, or solicit money or other tangible or intangible benefit in exchange for favorable decisions or actions in the performance of his or her job.
  • RF employees may not share with any individual or entity or transfer to any individual or entity (physically or electronically) any confidential company information, materials, processes, software or other business assets not authorized by the President or his designee to receive it, and must make every effort to safeguard such assets.

What RF employees MAY do:

  • RF employees may attend events, participate in activities, and accept items from an individual or entity with minimal value (an item or items whose aggregate value in a 12-month period is less than $75) within/from the Research Foundation, The City University of New York, or their related entities if a reasonable person would regard such actions as representing normal business practices not inconsistent with the other provisions of this policy.
  • RF employees may accept items of minimal value (see above) from other entities if they are reasonable and customary when given on special occasions or holidays.
  • RF employees may accept invitations to participate in professional meetings, seminars or conferences free of charge (including meals and refreshments) so long as all other participants receive like consideration. (RF employees may not, however, accept free lodging or travel.)


The provisions of this policy are effective January 1, 2007.

In the event that the terms of this policy are in conflict with any applicable Federal, State or local law, rule or regulation (statutory or decisional), the terms of the law, rule or regulation shall govern.

*This policy is not intended to apply to CUNY employees subject to University or governmental ethics policies.

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