As a public officer, you have a responsibility to act in an ethical manner in compliance
with New York state law and SUNY policy. By complying with the law, you avoid conflicts
of interest that undermine the public’s trust in our university and help to forge
a community built on shared values of honesty, trust and integrity.
As an employee of the university you are considered a public officer and are expected
to adhere to ethical standards outlined in New York state law. Enrollment in the annual
NYS Ethics Training will help you better understand your role and responsibilities
as a public officer. At the core of all ethical obligations is the prevention of actual and apparent conflicts
of interests between official duties and private interests. For clarification of roles and responsibilities, contact the campus ethics officer
Lauren Currie.
About New York State Commission On Ethics & Lobbying In Government
The New York State Commission on Ethics and Lobbying in Government (COELIG) was founded
by the Ethics Commission Reform Act of 2022. A goal of COELIG is to establish public
trust in government by ensuring compliance with ethics and lobbying laws. COELIGs
jurisdiction reaches over 300,000 NYS employees at state agencies and departments,
including SUNY. COELIG provides information, education and advice regarding ethics
laws and promotes compliance through audits, investigations and enforcement proceedings.
For transparency a state agencies policymakers and qualifying income threshold filers
are required to complete a financial disclosure statement annually. COELIG has a commitment
to ensuring state employees are acting in the public's best interest and exemplify
high ethical standards. The COELIG Code of Conduct is the most prominent standard
ever endorsed by an NYS ethics commission. Its purpose is to establish the highest
possible standards of public service to the people of New York and inform their practice
and performance of their official duties.
This law refers to restrictions on the business or professional activities of current
and former state employees, excluding unpaid and per-diem employees (“Covered Employees”).
Activities covered include: Outside employment and professional activities, restriction
on political activities, nepotism, gifts, honorarium, travel, negotiations on future
employment and post-employment restrictions.
Public Officers Law Section 73-A
This law refers to the annual Financial Disclosure Statement (“FDS”) required of certain
employees who are considered policymakers or whose salary is above certain thresholds.
This includes who is required to file a FDS, the questions to be answered on a Financial
Disclosure Statement, penalties for violating the section and how to apply for filing
exemptions or deletions.
Public Officers Law Section 74
This law refers to the state Code of Ethics and sets forth the standards to avoid
conflicts of interest. This includes expectations of impartiality, maintaining confidentiality,
properly stewarding state resources without securing unwarranted privileges or favors,
abstaining from financial conflicts and avoiding conduct that calls into question
your integrity.
Civil Service Law Section 107
This law, also known as the Little Hatch Act, prohibits certain political activities
and against improper influence.
The Code of Ethics, or Public Officers Law Section 74, is intended to prevent the
use of your official position or authority for the benefit of yourself or another.
The Code of Ethics not only addresses actual conflicts of interest, but also the perception of such conflicts when performing
the official duties. The Code of Ethics' guiding principles and what they mean for you are outlined below.
You should not accept outside employment or engage in any business or professional
activity that requires you to disclose confidential information you have received
in your state position.
You should not disclose confidential information you have received in your state position.
In addition, you should not use such confidential information to further your personal
interests.
You should not use or attempt to use your state position to secure unwarranted privileges
or exemptions for yourself or others. This includes, but is not limited to, the misappropriation
to yourself or others of the property, services, or other resources of the state for
private business or other compensated nongovernmental purposes.
If you are a full-time state employee, you are prohibited from contracting for the
provision of goods and services with entities regulated or licensed by your agency.
In addition, this prohibition applies to any entity in which you are a member, and
to any corporation a substantial portion of the stock of which is owned or controlled
directly or indirectly by you.
You should not engage in any transaction as representative or agent of the state with
any business entity in which you have direct or indirect financial interest that might
reasonably tend to conflict with the proper discharge of your state duties.
You should not make personal investments in enterprises that are directly related
to your state duties, or that would create a substantial conflict between your state
duties and your private interest.
In your personal and professional life, you should not conduct yourself in such a
way that gives the reasonable impression that a person or entity can improperly influence
you, or enjoy your favor, in the performance of your state duties.
You should conduct yourself in a manner that does not raise suspicion that you are
engaged in personal or official acts that are in violation of the public trust.
Requests To Make In Advance
For certain activities, requests must be made in advance to comply with legal restrictions
in state law and principles of ethical conduct.
The campus ethics officers and COELIG are here to help. When in doubt, ASK in advance!
An honorarium is any payment, which may take the form of a fee or any other compensation,
made to a covered person in consideration for a service performed that is not part
of his or her official duties. Such service includes, but is not limited to, delivering
a speech, writing, or publishing an article, or participating in any public or private
conference, convention, meeting, or similar event. Honorarium shall also include expenses
incurred for travel, lodging, and meals related to the service performed.
Request for approval must be submitted in writing to the campus ethics officers or
other designated persons before performing the service or activity. Statewide elected
officials and state agency heads (including civil department heads) must submit an
approval request to COELIG.
Exception: Teaching Faculty are exempt from the honoraria approval procedures (including the
conditions for approval) provided that the service performed is within the subject
matter of their official academic or research discipline.
Please Note: State officers and employees who are required to file a FDS — even those who are exempt
from the honorarium approval requirements — are obligated to report any honorarium
in excess of $1,000 (or all honoraria, the total of which exceed $1,000 received from
a single offeror) in their Financial Disclosure Statement (“FDS”) for the applicable
year.
Official activity expense payment is a payment or reimbursement for the cost of attendance,
registration, travel, food or lodging related to a covered employee’s official activity.
Official activity is a person’s attendance or service at a meeting, conference, seminar,
convention or professional program that is part of his or her official duties and
benefits their state agency.
An outside activity is any interest or activity not related to your state employment.
An activity may be an occupation, whether paid or unpaid, membership on a board or
volunteer work, etc. An outside activity occurs outside of your regular work hours
and without utilizing any government resources.
All covered employees should evaluate whether the intended outside activity is appropriate
under the rules of Public Officers Law § 73 and is not a conflict of interest under
the rules of Public Officers Law § 74.
Prior to engaging in any outside activities, all covered employees should seek advice
from their campus ethics officer or COELIG concerning the appropriateness of such
activities under the applicable laws and regulation.
Policymakers have an additional responsibility — they may require approval from their
campus, COELIG or both before pursuing an outside activity. In general, the approval
process is based on how much they anticipate earning through their intended outside
activity.
Annual Compensation Threshold Amounts for Policymakers
Greater than $1,000 — Request must be approved by campus ethics officer.
Greater than $5,000 — Requires COELIG approval as well as the campus ethics officer
prior approval submitted in the Outside Activity Approval Form.
Generally, you may accept anything valued at $15 or less. If a gift is offered by
an “interested source,” the acceptance of the gift is prohibited.
A gift includes, but is not limited to, money, services, loans, travel, meal refreshments,
entertainment, forbearance or a promise having a monetary value.
There are a number of requirements and exceptions when it comes to accepting a gift,
so before doing so speak to a campus ethics officer to determine whether or not the
gift is prohibited.
Certain SUNY Plattsburgh employees are required to file an annual financial disclosure
statement (“FDS”) and participate in periodic ethics training. Employees will be notified
by a campus ethics officer or by the New York state COELIG if they need to file and
complete the training.
With some exceptions, COELIG requires state employees with an annual salary over the
salary threshold ($115,252 as of 2025) to file a FDS every year.
Individuals designated as policy makers by their agency. SUNY Plattsburgh’s policy
makers are the president, vice presidents, deans, associate vice presidents and associate
deans; and
Employees with an annual salary rate in excess of the “filing rate” of a SG-24 CSEA
equivalent ($115,252 in 2025).
In general, part-time employees who serve in a position with an annual full-time salary
that exceeds the “filing rate“ are still required to file an FDS even if they actually
receive less than the “filing rate” amount in any year.
Who is Exempt from Filing
If you are not a policymaker, COELIG has the discretion to grant an exemption from
filing an FDS in its entirety if:
public interest does not require the filer’s FDS to be disclosed; and
the filer’s duties do not involve the negotiation, authorization, or approval of:
contracts, leases, franchises, revocable consents, concessions, variances, permits,
or licenses;
the purchase, sale, rental, or lease of real property, goods or services, or a contract
therefor;
the obtaining of grants of money or loans; or
the adoption or repeal of any rule or regulation having the force and effect of law;
An exemption from filing an FDS may be requested by an individual or by an agency
on behalf of a class of individuals in the same position.
The on-demand ethics training video should only be completed by employees who completed
live comprehensive ethics training (CETC) in the prior year with the COELIG Training
Team or the campus ethics officer.
Note: Employees may choose to satisfy this requirement by retaking the CETC instead of the
On-Demand Ethics Refresher.