Outside Employment Disclosure
While employees may hold employment outside of the CSU, outside employment must not interfere with an employee's ability to meet their CSU responsibilities or prevent them from acting in the best interest of the CSU.
State law (Title 5 California Code of Regulations § 42740) and CSU policy (HR 2016-06) require all Executive and Management Personnel Plan (MPP) employees to disclose any outside employment they have. Moreover, the employee’s HEERA manager is required to review the disclosure and determine whether the disclosed outside employment poses a conflict of interest or a conflict of commitment with the employee’s CSU position. If the HEERA manager identifies a conflict, then the employee is expected to manage, reduce or eliminate the outside employment to avoid the conflict.
Who
All Executive and MPP employees, both full-time and part-time employees as well as retired annuitants, are subject to the Outside Employment Disclosure requirements. Each Executive and MPP employee is individually responsible for ensuring that their outside employment activities do not create any actual or perceived conflict of commitment and/or conflict of interest to their CSU position. The employee must monitor their own activities and report any and all outside work for which they are compensated.
What
As defined by the policy, “outside employment” is any work for which a W-2 or 1099 is issued and that is not compensated through the CSU payroll. Outside employment includes work compensated by Cal Poly Pomona Enterprises or Associated Students, Inc. Examples of “outside employment” include, but are not limited to:
- Speeches/presentations at conferences
- Editorial work in books, journal articles or similar works
- Service on a nonprofit or for-profit board
- Service on a federal, state, or local committee/panel/commission
- Service as a consultant or an expert witness
Passive income (e.g., payments for services performed in the past, including royalties for writing, copyrighted work, research, and patented materials) is not reportable.
When
The outside employment disclosure form must be completed by Executive and MPP employees at the following times:
- At the time of the Executive or MPP appointment;
- Annually, even if there is no outside employment to report;
- Within 30 days of the employee’s accepting outside employment; and
- Within 10 days upon request by the employee’s HEERA manager
How
Employees make disclosures by using the form provided by Human Resources. On the disclosure form, the employee provides the requested information regarding the outside work. The description must contain sufficient details so that the employee’s HEERA manager can understand what the outside work entails and can determine whether the outside work poses a conflict interest or a conflict of commitment with the employee’s CPP job.
The HEERA manager reviews the information the employee discloses on the form and determines whether the outside work poses a conflict of interest or a conflict of commitment with the employee’s CPP position.
What
The HEERA manager’s determination on whether a conflict of interest exists is governed by the policy, which states, “No CSU . . . employee may make, participate in making, or influence a governmental decision in which he/she has a financial interest. . .. A conflict of interest exists if the outside employment creates a financial interest on the part of the employee that precludes the employee from making decisions within the scope of the employee’s duties.”
Regarding conflicts of commitment, the policy states:
Conflict of commitment may be found if the outside employment activity results in:
• A reduction of the employee's time and energy devoted to CSU activities
• The use of CSU property or other resources without authority (other than de minimus)
• An influence over the way the employee performs his/her CSU responsibilities
• The disclosure of confidential or proprietary information acquired through the performance of CSU duties
• Acting against the CSU's best interest or in conflict with the CSU's mission and goals
• The violation of CSU policies, procedures or practices
When
Upon receipt of the employee’s disclosure form, the HEERA manager reviews the disclosed information for conflicts of interest or commitment.
How
The HEERA manager indicates on the disclosure form whether or not there is a perceived or actual conflict of interest or conflict of commitment between the employee’s outside work and the employee’s CPP position.
If any perceived or actual conflict of commitment or interest is found, the employee and the HEERA manager discuss the actions the employee must take to manage, reduce or eliminate the outside employment to avoid the conflict.
If the discussion leads to an agreement, the HEERA manager documents on the disclosure form the measures that the employee has agreed to take.
If there is a disagreement between the employee and their HEERA manager on the existence of a conflict or on the measures to avoid the conflict, the HEERA manager would consult with hrpolicy@cpp.edu. An appeal committee will be appointed to review the matter and make the final decision.
There are two different versions of the Outside Employment Disclosure form. One version is for the Executives (aka Senior Management (SM)), including the vice presidents and the President. The second version is for Management Personnel Plan employees (MPPs).
Human Resources sends each MPP/Executive employee the Outside Employment Disclosure form to complete when the employee first enters their MPP/Executive position. In addition, Human Resources sends out the form in May/June every year for the annual filing.
If an employee needs to complete the form because they have just taken on outside employment or they have been requested by their HEERA manager to complete the form, please contact hrpolicy@cpp.edu to obtain the form.
Annually in May/June, Human Resources sends the Outside Employment Disclosure form to all MPP and Executive employees via Adobe Sign. Once the employee completes their section of the form, Adobe Sign routes the form to the employee’s HEERA manager to complete their respective section. When the form has been completed by both the employee and their HEERA manager, both individuals and Human Resources would receive a copy.
The 2025 Annual Outside Employment Disclosure covers calendar year 2024 employment activities.
The disclosure must be completed by both the employee and their HEERA manager no later than June 30, 2025.
As part of the CSU’s renewed commitment to the California Legislature to improve transparency and accountability, the Chancellor's Office posts the outside employment activities of all vice presidents and presidents on a public website. Moreover, all Outside Employment Disclosures are public documents that are subject to disclosure upon request to any member of the public.
Employees with questions regarding the policy should contact hrpolicy@cpp.edu.
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