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Conflict of Interest Policy

Approving Authority: President and Chief Executive Officer

Administrative Responsibility: Director, Policy Research and Advocacy

Original Approval Date: November 4th, 2024

Date of Most Recent Review/Revision:

Related Policies, Procedures, and Documents: 

  • Executive Limitation #1 - Global Executive Constraint

  • Executive Limitation #2b - Treatment of Staff

  • Executive Limitation #2f - Asset Protection

  • Executive Limitation #2l - General Meetings and Elections

  • Executive Limitation #2n - Hiring Practices - Paid Staff

  • Employee Standards and Performance Policy

  • Health and Safety Policy

  • Safe Disclosure Policy

1. Purpose

1.1. This policy provides guidance to Students’ Union employees about identifying, mitigating, or avoiding conflicts of interest. 

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2. Definitions

2.1. Conflict of interest: Occurs when personal interests or professional affiliations outside of the Students’ Union interfere, or are perceived to interfere, with the independent judgement required by employees to perform their duties and responsibilities.   

2.1.1. Conflicts of interest include, but are not limited to: 

2.1.1.1. An interest, real or perceived, that unfairly benefits the individual or their relative, friend, roommate, or romantic partner. 

2.1.1.2. Organizations, companies, or groups that an employee has an official governing responsibility or that employs the individual or a member of their family. 

2.1.1.3. Gifts and favours, including tokens of appreciation, entertainment, travel, hotel accommodations, services for personal use, reduced prices for personal goods and services, and any other forms of hospitality provided in hopes of future business. 

2.2. Employee: A paid worker of the Students’ Union.  

2.3. Supervisor: The individual to whom an employee directly reports, or their designate. 

2.4. Workplace: Any site at which the employee works, including any property or building utilized by the Students’ Union and any other place an employee is located while performing work for the Students’ Union or representing the organization. 

2.4.1. Workplace includes operating Students’ Union equipment or a personal vehicle while the employee is on duty. 

3. Jurisdiction/Scope

3.1. This policy applies to all Students' Union employees. 

4. Declaring a Conflict of Interest

4.1. Employees are required to declare to their supervisor any conflict of interest or other circumstance that may reasonably interfere, or be perceived to interfere, with their ability to perform their duties and responsibilities.  

4.1.1. Supervisors, in consultation with a Human Resources representative when appropriate, will determine the nature and extent of the conflict of interest and determine what steps are required to mitigate or avoid situations or responsibilities where that conflict will interfere with the employee’s duties. 

4.1.2. Employees may be required to refrain from taking part in a discussion, project, hiring process, or decision-making vote related to the conflict of interest.  

4.2. Human Resources may declare that an employee has a conflict of interest in the absence of a self-declaration.  

5. Reporting a Conflict of Interest

5.1. If an employee believes a conflict of interest has not been properly declared by another employee, they may make a good faith disclosure according to the Safe Disclosure Policy. 

6. Hiring Practices

6.1. Employees may be required to refrain from participating in a hiring process if a conflict of interest will interfere, or be perceived to interfere, with the fairness and legitimacy of the job search. 

6.1.1. Human Resources, in consultation with the President or Executive Director, may declare that an employee has a hiring conflict in the absence of a self-declaration and require that they be removed from the hiring process. 

6.2. For conflicts of interest related to Executive Leadership Team hiring, the President in consultation with Human Resources will determine if an employee must be removed from the hiring process. 

6.3. The Students’ Union may accept applications for employment from an employee’s immediate family so long as the successful hiring of that immediate family member does not result in supervisory relationship. 

7. Business Operations

7.1. Prior to entering a new contract with a vendor or supplier the due diligence conducted must include consideration of conflicts of interest. 

7.2. Contracts valued at $5,000 or more must proceed through a formal tender process to ensure procurement best practices and avoid conflicts of interest.

8. Employee Relationships

8.1. Acknowledged employee romantic relationships are not considered a conflict of interest so long as they do not include a supervisory relationship and are disclosed with Human Resources.  

8.1.1. Employee romantic relationships that are not disclosed may represent a conflict of interest. 

9. Secondary Employment

9.1. Secondary employment is permitted so long as there are no adverse effects to the employee’s ability to perform their duties and responsibilities and it does not represent a conflict of interest.  

9.1.1. Employees are encouraged to discuss secondary employment opportunities in advance with their supervisor.  

Waterloo Office

2nd Floor, Fred Nichols Campus Centre
75 University Ave. W, Waterloo, N2L 3C5

General Inquiries: 1.548.889.5583

Health & Dental Plan/SU Desk: 1.548.889.4389
Office Hours: Monday - Friday 9 a.m. - 4 p.m.

Wilf's Restaurant: wilfs@wlu.ca (Reservations to be made through email)

Brantford Office

1st Floor, Student Centre
103 Darling Street, Brantford, N3T 2K8

General Inquiries: 1.548.889.5583

Health & Dental Plan/SU Desk: 1.548.889.3676
Office Hours:  
Monday - Friday  10 a.m. - 4 p.m.

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