2.19 | Conflict of Interest and Conflict of Commitment

Sampoerna University is a community of scholars, learners, and leaders dedicated to advancing its students’ and employees’ intellectual and ethical capacities by discovering, creating, and sharing knowledge. Members of Sampoerna University community are expected to be honest and supportive of its mission in their relationships with each other, the University, and outside organizations. The policies, principles, and responsibilities for recognizing, eliminating, limiting, and managing actual, potential, or apparent conflicts of interest or commitment among members of the SU community are outlined here.

2.19.1 | To Whom the Policy Applies

This policy applies to all members of the Sampoerna University community, and they must report any potential, actual, or perceived conflicts to the appropriate University representative. When a conflict of interest exists or may occur, some members of the SU community may be asked to step down from debate, voting, or other decision-making processes.

All decisions and actions done by members of the Sampoerna University community in the conduct of university business, research, or other activities should serve the University’s best interests. Members of the SU community are responsible for appropriately resolving both the substance and appearance of a conflict of interest or commitment.

A conflict of interest is a set of circumstances that creates a risk that professional judgment or actions regarding a university interest will be unduly influenced by a secondary or personal interest.  Members of the Sampoerna University community are obligated to avoid or disclose actual ethical, legal, financial, or other conflicts of interest involving the University, and recuse themselves when decision-making related to university responsibilities could be influenced by a conflict of interest.

A conflict of commitment occurs when outside activities interfere with an individual’s ability to meet University responsibilities.  Members of the SU community are expected to commit their time and intellectual energy toward supporting the mission of the University, consistent with their employment or appointment.

The full disclosure of interests and activities that may give rise to actual, potential, or perceived conflicts is necessary to determine if it is permitted, and if so, the necessary actions to ensure it do not result in actions or conditions which conflict with the University’s mission, strategy or operations.

2.19.2 | Personal Relationships in the Workplace

Members of the SU community are not permitted to participate in decision-making or evaluations, nor may they authorize the use of university funds for activities that directly benefit family members (e.g., initial employment, salary, work assignments, performance evaluations, University-sponsored travel, teaching assignments).

2.19.3 | Business Decisions

Members of the SU community may not make or influence business that benefits them, a family member, or an associate, including negotiating purchase agreements or other types of contracts. Members of the SU community who stand to benefit from a contract must inform their supervisor about it.

2.19.4 | Use of the University Name or Likeness

The University name, likeness, or logo may only be used in the context of university responsibilities by members of the SU community. The name and logo of the university are registered trademarks of the university.

2.19.4.1 | Personal Gifts

In most circumstances outlined below, members of the SU community are prohibited from accepting personal gifts and favours from a donor; current, prospective, or former student or parent; or others with whom there is a potential or existing business or professional relationship, to avoid a conflict of interest or the appearance of a conflict of interest.

1. Prohibited Personal Gifts
   Gifts valued more than IDR 1 Mio must be returned immediately.
2. Acceptable Personal Gifts
   1. Gifts valued up to and including IDR 1 million, but if accepted, the individual should report the gift to their supervisor when received, and the gift must be reported on the Conflict of Interest and Commitment Disclosure form.
   2. Gifts of promotional items of nominal value and that are routinely distributed by vendors to clients (e.g. pens, notebooks, tote bags, etc.).
   3. Modest gift baskets or nominal food items that are shared widely by colleagues.
   4. Courtesy copies of professional materials and publications.
3. Service on University Committees
   A member of the Sampoerna University community functioning on a university committee must either recuse themselves or disclose to the committee chair any interest or relationship that could result in a possible or actual conflict of interest, so the conflict is appropriately addressed.
4. Responsibilities
   Any member of the SU community who is unsure about what constitutes a conflict should consult their supervisor or other authorized authority and report any actual, possible, or perceived conflicts as required by this policy.
5. Reporting
   All members of the SU community must report possible, actual, or perceived conflicts to their supervisor as soon as they emerge, and the supervisor must ensure that the conflicts are documented and addressed by the applicable reporting and review process. Certain members of the SU community (such as the Rectorate, Deans, etc.) are expected to submit annual disclosure forms and to update them as conflicts or potential conflicts arise.
6. Review
   Human Resources oversees and is responsible for:
   • It conducts conflict of interest and commitment reviews to comply with any policies and standards that apply.
   • It is assuring that management plans are in place and documented for any reported conditions or situations that appear to generate conflicts of interest or commitment.
   • As circumstances dictate, providing appropriate oversight of discovered conflicts of interest or commitments, as well as associated management plans, with other University officials and offices to ensure that each possible or actual conflict is examined, addressed, or managed.
7. Consequences for Violating this Policy
   Failure to comply with this and associated rules may result in disciplinary action, including suspension without pay or termination of employment or relationship with the University, in line with applicable disciplinary procedures (e.g., lecturers, staff, students).