Conflict of Interest Policies for Monthly Paid Employees: Teaching & Other Extramural Activities

You should be aware of the policy concerning additional pay for staff members (monthly paid and weekly paid) issued by Wharton’s Department of Human Resources. All persons supervising  monthly paid and weekly paid staff have the responsibility of understanding this policy, of communicating it to affected staff, and of enforcing it. Supervisors have no discretion to grant exceptions on their own. [The process for obtaining approval of an exception is described below.]Since a number of monthly paid employees teach classes, we wish to point out how this policy relates to staff members who take on teaching commitments. These policies apply to such persons, regardless of whether or not a monthly paid employee also holds an adjunct appointment in the Associated Faculty. Thus, the necessary approval of such activity must be secured. You should also be familiar with the Advance Approval Procedures. Please use this online resource when seeking approval of a staff member’s extramural activity.

PennWorks Additional Pay Pre-Work Approval Features

Below are the relevant statements of policy for both the University and the School. Supervisors of monthly paid employees who teach are required to make their employees aware of these policies.

Review of University Policy – University policy states that “employees of the University shall avoid any conflict between their personal interests and the interests of the University; furthermore, they shall avoid any situation where it would be reasonable for an objective observer to believe that the person’s judgment or loyalty might be adversely affected.” (Policy 005, “Conflict of Interest”) It is therefore expected that employees will not engage in any activities which are in competition with those activities which are part of the mission of the University or of the Wharton School. The full University policies concerning extramural activities and conflict of interest (policies #005 and #006) are attached.

Review of Wharton Policy – Monthly Paid employees are expected to work a minimum of a 9-to-5, Monday-Friday, workday. They are therefore prohibited from accepting any extramural commitments, including teaching, for which they would receive extra compensation and which would require them to work for any other entity other than their home unit during regular work hours. This includes teaching commitments, whether in Wharton, elsewhere in the University, or for another institution. Any compensation for teaching performed during regular working hours must therefore be made in the form of a buy-out of salary. Exceptions to this may be made only if the commitment is approved by (1) the Deputy Dean, (2) the Associate Dean for Finance and Administration, (3) Wharton Human Resources, and (4) the employee’s supervisor. Any such arrangements must be documented in writing, with a copy filed with Wharton’s Human Resources Office.

Monthly Paid employees should not accept any teaching assignment, even if the class occurs after normal working hours, without first consulting with their supervisors and ascertaining whether the assignment is likely to receive approval. Employees who are approved to teach after normal working hours are prohibited from engaging in tasks related to that teaching (i.e., grading exams and papers, holding office hours) during normal working hours.

Monthly Paid employees who wish to teach for an extended period, i.e., for a summer program, may use their vacation time or apply for an unpaid leave for the duration of the program. Whether such a leave is granted is at the discretion of the employee’s supervisor, and it should be noted that there is no guarantee that such a leave will be granted. An employee must contact Wharton Human Resources to begin the process of applying for an unpaid leave at least one month before the leave commences. A copy the policy issued by Wharton’s Department of Human Resources is attached for reference.

Wharton Internal Procedures Supporting University Policy 305.3 Extra Compensation – Extra Pay Additional Payment/Exempt Professional Staff
Additional pay may be awarded for completion of a special assignment or for projects which are completely outside the scope of the individual’s job duties, and typically are not performed on a continuing basis. Before an employee can be approached with an opportunity to assume a special assignment, the department head, or representative of the department seeking the services, must meet with Wharton Human Resources. Human resources will review the request with the associate dean of Finance and Administration. If approved, a written request from the department head of the group receiving the service must be given to the staff member’s supervisor. The supervisor and employee should sign off on the request and forward a copy to Wharton’s Human Resources.

In the original request, the department head should include the estimated amount of hours assigned to the project and the amount of additional pay being granted to the staff member. It is important that all parties involved agree that work on the project will be done on the employee’s non-work hours. Work on the project should not begin until approval is secured from the department head and staff member’s supervisor.

Request for payment is submitted on an “Additional Pay Form” by the department receiving the service. The completed form is forwarded to Wharton’s assistant director of Human Resources along with any supporting information.

Failure to follow the above procedures can result in disciplinary action.

University Policy 305.6 Extra Compensation Exceptions – Extra Payment/Non-Exempt Support Staff
Extra compensation programs cannot be used to compensate non-exempt (G grades) employees in lieu of overtime pay (hours worked in excess of forty hours per week). Overtime must have prior approval from, or be requested by, the staff member’s supervisor. Non-exempt employees are covered by the Fair Labor Standards Act (FLSA).

Overtime should be reflected on the staff members time report. The employee’s supervisor must sign off on the time report before it is entered into the system. On-line time reporting is the method used to process overtime/extra pay for non-exempt personnel.

The information must be entered into the database within the same pay period that the overtime is worked.   Failure to secure proper approval can result in disciplinary action.