Conflict of Interest

Under state law and CSU Conflict of Interest policy, no University employee shall make, participate in making, or attempt to use his or her position to influence a University decision in which he or she has a personal financial interest. No University employee shall vote, make recommendations, or in any way participate in a University decision that could pose a material conflict of interests. 

If it is foreseeable that the employee will make or influence a University decision that could affect any of their economic interests, such as business or real estate investments, income, gifts, and management positions held in a business, then the employee must notify the University of this potential conflict of interests. If the University determines that the effect is both foreseeable and material, the employee would be disqualified from the decision-making process.This disqualification rule applies to all CSU employees, regardless of whether they file Form 700.

For more information, see Conflict of Interest Handbook (PDF)

In compliance with state law and the CSU Conflict of Interest policy, each CSU campus has identified the positions that are most likely to be involved in university decision-making.  These positions are referred to as “designated positions.” 

Collectively, the lists of designated positions at all CSU campuses are known as the CSU Conflict of Interest (COI) Code. The CSU COI Code is published by the Chancellor’s Office.  Occasionally, the CSU amends it.  The most recent CSU COI Code amendment became effective on January 7, 2024.  More information is provided on the January 2024 amendment page.

Employees and consultants, who hold designated positions, are referred to as “designated employees” and “designated consultants,” respectively. Not all employees or consultants are designated.

Designated employees and consultants must periodically file a financial interest disclosure, called Form 700, and complete ethics training.

Form 700
Per state law and the CSU Conflict of Interest policy, employees and consultants, who hold positions that are designated in the CSU Conflict of Interest (COI) Code, must file the Statement of Economic Interests – Form 700.

When must Form 700 be filed?

• Entering Position: Employees and consultants must file Form 700 within 30 days of entering a designated position.
• Annual Filing: Current incumbents in designated positions must file Form 700 each year by April 1st.  
• Leaving Office: When a current incumbent leaves their designated position, they must file Form 700 within 30 days of leaving office.

• A business position (e.g., a director, officer, partner, trustee, employee, or management), whether paid or not
• Income of $500 or more
• Gifts totaling $50 or more
• Investments of $2000 or more
• Real property interests (this is only required of designated employees and consultants who are assigned to disclosure category 1 or 3)

A “reportable source” is any entity which is of the type that, in the last two calendar years, has done business with the University in the work area(s) over which the designated employee or consultant has decision-making authority or influence. 

Below is a table contained in the Form 700 filing instructions that summarizes the common financial interests that must be reported and those that do not have to be reported.   

Form 700 Resources
This webpage and the resources listed below are provided to help designated employees and consultants understand the general reporting requirements. However, it is important for each designated employee and consultant to make every effort to understand what the form requires in their specific circumstance since they must verify the content of their own Form 700 under penalty of perjury.

For specific guidance, designated employees and consultants should contact the Fair Political Practices Commission (FPPC), the state agency responsible for administering the Political Reform Act of 1974.
 

What is the purpose of filing Form 700?
The purpose of Form 700 is to alert designated employees and consultants to their personal financial interests that might be affected while they are performing their official duties. If and when they are called upon to make or participate in making a particular decision that could foreseeably affect a financial interest of theirs, they must notify the University, who will then engage in an analysis to determine whether the employee/consultant must recuse themselves from the decision.
 
Form 700 also provides information to members of the public who may monitor official actions for any conflicts.

In compliance with state law and CSU policy, employees and consultants in designated positions must complete ethics training within six (6) months of entering their designated position. Training is also required every two years thereafter. This is a web-based training offered through the CPP Learning Portal and may be taken from any computer with Internet access.

How to Take the Online Training: Employees and consultants in designated positions may access the training through a link in the email notification that they receive from CPP Learning or follow the below instructions:   

1. Click on this hyperlink - CPP Learning Portal
2. Login using your Bronco ID and Bronco Password
3. Bottom left of the screen, click on 'Assigned Learning'
4. Select 'Avoiding Conflicts of Interest' course
5. Click on 'Register/Register Again'
6. Click on 'Start' to launch the course

Employees and consultants holding designated positions are notified of the requirements to file Form 700 and take ethics training via:

• The Job Announcement and Job Description;
• Email communications from the CSU's online Form 700 filing system, called eDisclosure; and
• Email communications from the CPP learning management system, called CPP Learning

The Fair Political Practices Commission (FPPC) regulations and CSU policy on Gifts to Agency, Distribution of Tickets, and Reporting of Ceremonial Roles establish reporting requirements of gifts and tickets received by designated employees.

In general, if a designated employee received a gift or gifts totaling $50 or more in a calendar year from a reportable source, the designated employee must disclose the gift(s) on their annual Form 700. 

However, under the limited circumstances discussed below, payments made to the CSU by an outside source that are used by CSU employees to conduct CSU business or to achieve a stated public purpose would not be reported on Form 700 by the CSU employee who uses them;

• Form 801 (PDF). This form covers gifts made to the University, which are used by one or more employees to conduct University business, and where the donor had no control as to who received the gift. This may include travel payments, reimbursements, or other uses by employees (other than tickets or passes). If the gift meets the requirements of FPPC Regulations 18944 (PDF) or 18950.1 (PDF), the University must report it on Form 801 instead of the designated employee reporting it on Form 700. 

  • If the gift involves travel payments for a University business trip, the University must approve the travel in advance and in writing using a Gift to Agency Travel Request Form or a similar form. 

  • CSU employees who invest CSU funds are prohibited from receiving a gift of travel as a gift to agency unless the transportation, lodging, and food is directly related to the official's public duties, is for a purpose that would otherwise be paid for with the agency's funds, is authorized in the same manner as transportation, lodging, and food using the agency's own funds and otherwise meets the criteria for gifts to agency. 2 CCR §18944(e) (PDF).

  • When a donor hosts an employee as a guest at a University fundraising event. The value of the meal need not be reported on Form 801 or Form 700 provided the meal is received in the course of the University's own fundraising event and qualifies as a charitable deduction for educational purposes. 2 CCR §18944(e) (PDF).

• Form 802 covers tickets or passes to an entertainment or sporting event given to the University by an outside source and provided to a CSU employee to achieve a stated public purpose. If the ticket or pass is distributed according to the policy on Gifts to Agency, Distribution of Tickets, and Reporting of Ceremonial Roles and meets the requirements of FPPC Regulation 18944.1 (PDF), the University must report it on Form 802 instead of the designated employee reporting it on Form 700. Form 802 is also used to report tickets provided to CSU employees who perform a ceremonial role at an event on behalf of the CSU.

• The Fair Political Practices Commission (FPPC)
• Form 700 (Statement of Economic Interests) (PDF)
• Form 700 Reference Pamphlet (PDF) 
• Form 700 Frequently Asked Questions (PDF)
• Form 801 Payment to Agency Report (PDF)
• Form 802 Agency Report of: Ceremonial Role Events and Ticket/Pass Distributions (PDF)
• Limitations and Restrictions on Gifts, Honoraria, Travel and Loans (PDF)
• Gift of Travel for a Public Purpose Paid for by a 501(c)(3) or Government Entity (PDF)
• Guidelines for Waiving Late Fines (Form 700) (PDF)
• Statement of Economic Interests for Principal Investigators Form 700-U (PDF)

• CSU Conflict of Interest Home Page
• CSU Conflict of Interest Policy
• CSU Conflict of Interest Handbook (PDF)
• CSU Policy on Gifts to Agency, Distribution of Tickets, and Reporting of Ceremonial Roles

• Conflict of Interest Form 700 Filing Webinar (Cal Poly Pomona, March 2024)
  • Slides (PDF)
  • Conflict of Interest Form 700 Webinar

• Cal Poly Pomona’s Conflict of Interest Filing Officer:
  Ellen Bui
  HR Policy & Audit Readiness Analyst
  (909) 869.3938
  hrpolicy@cpp.edu