Private Loans

An actual or potential conflict of interest may occur when an individual is in a position to influence the College’s business dealings so as to produce personal gain or gain for a relative, friend, or business associate of that individual. Personal gain may result not only in cases where a person acting for or on behalf of the College (or a relative, friend, or business associate of such a person) has significant ownership in a firm with which the College does business, but also when a substantial gift or special consideration is received as a result of any transaction or business dealing involving the College. For the purpose of this policy, a relative is a member of the individual’s immediate family.

All employees and certain volunteers acting for or on behalf of Sarah Lawrence College have an obligation to conduct business for or on behalf of the College in a manner that avoids actual or potential conflicts of interest. Further, trustees, senior officers, and key administrators of the College, as well as non-trustee members of the College’s Board of Trustee’s Finance Committee, are required to disclose relationships that create or appear to create such conflicts of interest.

Trustees, non-trustee members of the Board of Trustee’s Finance Committee, senior officers, and key administrators who have significant business affiliations or official relationships with organizations with which the College does business are required to disclose those affiliations. In this context, “official relationship” means serving as an officer, director, employee, partner, or proprietor of an entity that transacts business with the College, or owning minimum 10 percent of the entity’s stock. A conflict of interest is not always created by the mere existence of a relationship with outside organizations. However, if an individual has influence at the College on any commercial transactions, including but not limited to purchases, contracts, or leases, it is imperative that he or she disclose as soon as possible the existence of such relationships so that safeguards can be established that will prevent any conflict of interest from arising. Such safeguards may include, without limit, the recusal of such individual from decision-making on any matter under consideration by the College or before the Board of Trustees.

Each year the Secretary of the Board will provide trustees, non-trustee members of the Board of Trustee’s Finance Committee, senior officers, and key administrators with the policy statement, a disclosure form, and a current list of organizations with which the College does substantial business. The Secretary of the Board will compile the results of the disclosure process, providing information to the Chairman of the Board, the President, the Chairman of the Audit Committee, and the Vice President for Finance and Administration. All information provided in response to this request shall be held in confidence unless the best interests of the College dictate otherwise and except as required by law.

The acceptance of gifts from persons or entities doing business or seeking to do business with the College can create, or appear to create, a conflict of interest. Trustees, non-trustee members of the Board of Trustee’s Finance Committee, and College employees are therefore prohibited from soliciting or accepting any remuneration, gift, gratuity, services, loans, travel, entertainment, or other item, of more than nominal value from any person or entity doing business with or seeking to do business with the College. “Nominal value” as used in this policy, shall mean a value of $75.