Conflict of Interest

Political Reform Act of 1974


The Fair Political Practices Commission - The Political Reform Act requires CSU, as an agency, to adopt and communicate Conflict of Interest (COI) codes. The Act contains a general prohibition against conflicts of interest. Conflict of Interest law seeks to minimize the extent to which public employees pursue their own financial interests at the expense of the public interest.

Under the Act, no CSU employee shall make, participate in making, or attempt to use their official position to influence a CSU decision in which they have a financial interest. University employees shall not vote, make recommendations, or in any way participate in personnel or financial decisions if such participation constitutes a conflict of interest.

 

Filing Requirements


Good news! The Chancellor’s Office recently established a systemwide contract with Granicus to provide DisclosureDocs, an FPPC approved electronic Form 700 filing system, for CSU employees in a designated position. Beginning with this year’s 2021 annual filing period, filers will have the opportunity to use eDisclosure to electronically file Form 700. Filers will receive an email from Form700.CSU@southtechhosting.com that provides information about the filing requirements and a link to file Form 700 electronically.

Annual Filing and Training - The CSU Conflict of Interest Code requires employees in designated positions to file an electronic Form 700: 2020/2021 Statement of Economic Interests on an annual basis and take training within 6 months of assuming office and two years thereafter.

 

Late Filing


Employees who fail to timely file their electronic Form 700 may be referred to the FPPC's Enforcement Division (and, in some cases, to the Attorney General or district attorney) for investigation and possible prosecution. Employees are subject to a $10 per day fine up to a maximum of $100 for the late filing of a statement of economic interests Form 700 [pdf] (Govt. Code Section 91013). In addition, the President and/or Chancellor may be notified of the late filers. Employees who fail to file a Form 700 [pdf], or who fail to disclose material interests may be subject to a personal penalty. Penalties include disciplinary action against the employee, as well as potential civil & criminal penalties. More information on late filing can be found in the Conflict of Interest Handbook [pdf] (requires SJSUOne/CSU login)

 

Notification


New employees in designated positions or current employees newly appointed to designated positions are notified about their requirement to file and take training in the following ways: email from the campus Conflict of Interest Program Officer and from Form700.CSU@southtechhosting.com that provides information about the filing requirements and a link to file Form 700 electronically.

 

Questions


For additional information about compliance requirements, contact Magdalena Carrera, Coordinator of Online Training & Compliance, via email (up-compliance@sjsu.edu) or phone (408-924-2256).