110.0 CONFLICT OF INTEREST

INTRODUCTION

AUS insists that all of its employees exhibit the highest level of ethical conduct in conducting their day-to-day business with vendors, employees or professional organizations

PURPOSE

Provide employees with guidelines relating to what is and what is not acceptable behavior with respect to ethical conduct in dealing with employees, vendors, professional associations and other outside groups. All employees must avoid activities or relationships that conflict with AUS’ interests or adversely affect AUS’ reputation. The types of activities and relationships employees must avoid include, but are not limited to:

1. Accepting or soliciting a gift, favor, or service that is intended to, or might appear to, influence the employee's decision- making or professional conduct

2. Accepting, agreeing to accept, or soliciting money or other tangible or intangible benefit in exchange for the employee's favorable decisions or actions in the performance of his or her job

3. Accepting employment or compensation or engaging in any business or professional activity that might require disclosure of AUS’ business operation

4. Disclosure of confidential information or using it to their own personal advantage

5. Accepting employment or compensation that could reasonably be expected to impair the individual's independent judgment in the performance of official duties

6. Making personal investments that are contrary to the AUS’ interests

Employees must disclose actual or potential conflicts to their supervisor as soon as they become aware of them. Failure to make required disclosures or resolve conflicts of interest satisfactorily can result in discipline, up to and including termination of employment.

SCOPE

General Guidelines

The following policy applies to all employees.

Employees must not engage in any activities, transactions, or relationships that are incompatible with the impartial, objective, and effective performance of their duties. Examples of matters and relationships that could create a conflict of interest or a potential conflict, include, but are not limited to, when an employee or a member of the employee's immediate family:

• Accepts or solicits a gift, favor, or service from an individual, business, or other party involved, or potentially involved, in a contract or transaction with AUS
• Accepts, agrees to accept, or solicits money or other tangible or intangible benefit in exchange for the exercise of official powers or the performance of official responsibilities
• Accepts employment or compensation or engages in any business or professional activity that might require disclosure of AUS’ confidential information
• Accepts other employment or compensation that could reasonably be expected to impair the individual's independence of judgment in the performance of official duties
• Makes personal investments that are contrary to the AUS' interests.

PROCEDURES

Permitted Investments

Employees must avoid any investments in the businesses of AUS’ customers, suppliers, or competitors that could cause divided loyalty, or even the appearance of divided loyalty.

Employees who have investments in the businesses of AUS’ customers, suppliers, or competitors or who plan to make such investments must file a Conflict of Interest Disclosure Form. As a general rule, an employee's investment in securities traded on a recognized stock exchange does not create a conflict of interest as long as the securities are purchased on the same terms and with the same information available to the general public.

Disclosures

Employees are required to inform their department head as soon as they have knowledge of an AUS transaction or proposed transaction with an outside individual, business, or other organization that would create a conflict of interest or the appearance of one. Specifically, the employee is required to disclose any:

• Remuneration to the employee, or to an immediate family member, received from the individual/organization
• Investments or ownership interests the employee or an immediate family member has in the outside organization;
• Offices or positions the employee or an immediate family member holds in the outside organization; and
• Other relationships with the individual/organization that actually or potentially create a conflict of interest

All disclosures required under this policy must be directed in writing to the employee's department head. The departments head promptly reviews the disclosure and determines which interests are in conflict and which, if any, can be resolved.
Officers of AUS and any employees who purchase goods or services for AUS or who enter into and administer contracts on behalf of AUS must complete and file an annual Conflict of Interest Disclosure Form.

Confidentiality

To encourage the full disclosure of potential conflicts, disclosures are treated confidentially. Information provided on Conflict of Interest Disclosure Forms is available only on a need-to-know basis.

Withdrawal from Decisions

Employees are prohibited from exercising decision- making authority or exerting influence concerning any organization or transaction in which they or a family member have a personal interest. Employees must disclose such interest by filing a Conflict of Interest Disclosure Form with the appropriate department head and have that individual approve any arrangement for resolving the conflict including the employee's withdrawal from decision- making in the matter.

Misuse of Information

As a result of service at AUS, no employee shall use, for personal gain or for the gain of others, any information not available to the public. No employee shall personally exploit any business opportunity in which the employee knows or reasonably should know AUS is or would be interested, unless AUS first consents thereto in writing.

Gifts and Favors

No employee shall solicit or accept for personal use, or for the use of others, any gift, favor, loan, gratuity, reward, promise of future employment, or any other thing of monetary value that might influence or appear to influence the judgment or conduct of the employee in the performance of his/her job. Employees can accept occasional unsolicited courtesy gifts or favors (such as business lunches, tickets to sporting events, or holiday baskets) as long as the gifts or favors have a market value under $200, are customary in the industry, and do not influence or appear to influence the judgment or conduct of the employee in AUS’ business. An employee can be exempted from the restrictions in this paragraph by his/her supervisor as to a specified gift or favor. The exemption must be in writing and include sufficient justification. Individual administrative units within AUS can impose further restrictions on gifts or favors for its employees.

Work with Professional Organizations/ Associations

An employee's work with or for an outside professional organization or association does not create a conflict of interest if such work:

• Is related to the legitimate professional interest and development of the employee
• Does not interfere with the employee's regular duties
• Does not use AUS’ materials, facilities, or resources except as provided in AUS' personal use of facilities policy
• Does not compete with the work of AUS and is not otherwise contrary to the best interests of AUS
• Does not violate any UAE/US laws.

Reporting Suspected Violations

Alleged violations of this policy and the basis for the allegations shall be communicated confidentially and preferably (but not necessarily) in writing to the employee's supervisor or, the appropriate vice chancellor’s office. Measures must be taken to ensure that no adverse action is taken, either directly or indirectly, against a complainant who makes allegations in good faith.

Discipline

Engaging in any activity, transaction, or relationship that is adverse to AUS interests or failing to make disclosures required by this policy can result in immediate discipline, up to and including termination of employment. AUS can discipline an employee immediately when AUS has knowledge that the employee has engaged in activity prohibited by this policy. AUS exercise of such discipline does not depend on the disclosure process outlined in this policy.