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Compliance Certification Report
Comprehensive Standards 3.2.3


Last Updated Aug 13, 2004
(static edition)


Comprehensive Standards 3.2.3:

The board has a policy addressing conflict of interest.

The Institution Certifies Compliance: Yes

Compliance report completed by: Audit Team 10

Statement of Rationale for Judgment of Compliance:

Conflict of interest is addressed by Tennessee Board of Regents (TBR) policy. [1] Members of TBR and all employees of the system are responsible for avoiding activities and situations that put personal interest before the professional obligations they owe to the state and its citizens. Conflict of interest may arise when board members or institutional staff:

  • have direct or indirect financial interest in a contract or transaction,
  • participate in actions or decisions that involve a personal gain or advantage,
  • obtain personal gain with a concurrent adverse effect or impact on the system's best interests, or
  • obtain or assist improper third party gains from the system.

The TBR policy requires board members and selected staff of both the board and system institutions to file formal disclosure statements in January of each year (the disclosure is Attachment C of the TBR Policy [1]). Individuals who are required to file these disclosure statements must report any activity constituting a potential conflict of interest. Private interests that could result in personal gain, financial or otherwise, are disclosed so that potential conflicts with professional obligations and public trust are monitored. These statements include identifying relationships or business affiliations where the individual or immediate family member is an officer, director, trustee, partner, employee, or agent of such an organization; is the actual or beneficial owner of more than four percent of the voting stock or controlling interest of such organization; and/or has any other direct or indirect dealings from which material benefits are received.

Conflict of interest and financial disclosures are also addressed in the TBR Policy on Code of Ethics for Members of the Board. [2]


Relevant Organizational Unit(s):

Tennessee Board of Regents; Office of the President


Supporting Documentation and Evidence:

[1] TBR Policy 1:02:03:10 Conflict of Interest
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[2] TBR Policy 1:02:03:20 Code of Ethics for Members of TBR
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