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HomeMy WebLinkAbout1746 PrincesPHONE: 717 -783 -1610 TOLL FREE: 1 -800- 932 -0936 In Re: Carolyn Princes, Respondent t� r '4 � STATE ETHICS COMMISSION FINANCE BUILDING 613 NORTH STREET, ROOM 309 HARRISBURG, PA 17120 -0400 File Docket: X -ref: Date Decided: Date Mailed: FACSIMILE: 717-787-0806 WEBSITE: www.ethics.pe.gov 16 -002 Order No. 1746 216119 2111/19 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Melanie DePalma Monique Myatt Galloway Michael A. Schwartz Shelley Y. Simms This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seg., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its Investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was filed and a hearing was requested. A Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. ALLEGATIONS: That Carolyn Princes, a public official /public employee in her capacity as the Inclusion and Multicultural Programming Specialist, serving as the Director of the African American Cultural Center ( "AACC "), for the Indiana University f Pennsylvania ( "IUP ") violated [Sections 1103(a), 1103ff), 1105(a), 1105 b) {5), and y 1105(b)(8 of the State Ethics Act (Act 93 of 1998), [65 a.C.S. §§ 1103 {a1, 03(f), 1105(a), 1 05(b)(5), and 1105(b)(8)1: (1) When she utilized the authority of her public employment position for the private pecuniary benefit of herself, a member of her Immediate family namely her son, Maine Prince), and/or a business with which she]/immediate family is associated (namely Prince Management Group "PMG ") , when she awarded and/or entered into contracts between IUP /AACC and Maine Prince /Prince Management Group (PMG); (2) When she utilized the authority of her public position to award and /or enter into contracts valued in excess of $500.00, between IUP /AACC and Maine Prince /Prince Management Group ( "PMG "), a business with which her son and member of her Immediate family is associated, absent an open and public process; (3) When she utilized the authority of her public employment position for the private pecuniary benefit of herself, a member of her Immediate family Princes, 16 -002 a' ge T [namely her brother, Danny Wilbon), and/or a business with which she] /immediate family is associated (namely "The Mistery Band`, when she awarded and/or entered into contracts between IUP /AACC and he Mistery Band, (4) When, as the Inclusion and Multicultural Programming Specialist/Director of the AACC, she failed to identify all reportable sources of income on Statements of Financial Interests filed in connection with her public employment, for calendar years 2010, 2011, 2012, 2013, and 2014; and (5) When, as the Inclusion and Multicultural Programming Specialist/Director of the AACC, she failed to identify her office, directorship and /or employment, namely her office of President held with the Indiana Penna. Chapter of the NAACP on Statements of Financial Interests filed in connection with her public employment, for calendar years 2012 and 2014. II. FINDINGS; 1. Dr, Carolyn Princes ( "Respondent" or "Princes ") had been employed at Indiana University of Pennsylvania (hereafter, "IUP ") as the Director of the African American Cultural Center ( "AACC ") from September 17, 1990, until April 15, 2016. a. Princes was associated with numerous IUP student organizations, in part due to her employment as the Director of the AACC. b. Princes' most recent position, effective July 1, 2013, was as the Inclusion and Multicultural Programming Specialist - Cultural Center Director (hereafter, "Director "). 1. Although Princes' job title has been renamed throughout her tenure, she has consistently been employed as the Director. C. Princes was terminated from the Director position effective April 15, 2016. 1. [UP was ordered to reinstate Princes without backpay and without a loss in seniority pursuant to an arbitration award on September 17, 2018. 2. IUP was founded in 1875 as the Indiana Normal School. a. In 1965, after having gone through several name changes, the school was renamed "Indiana University of Pennsylvania." 1. In 1965 IUP became a member of the newly formed Pennsylvania State System of Higher Education (hereafter, "PASSHE "). 3. IUP's main campus is located in Indiana, Pennsylvania. a. lUP enrollment in the fall semester of 2015 was 13,775 students. b. IUP offers undergraduate, masters, and doctoral degree programs and is accredited by the Middle States Association Commission on Higher Education. 4. The Black Cultural Center was established at IUP in the 1970s. to provide a variety of social, educational, cultural, and recreational activities in an effort to enhance the educational experience at IUP for African American students. Princes, 16 -002 Page '3 a. In 1995 the Black Cultural Center was renamed the "African American Cultural Center" ( "AACC "). 5. The AACC mission statement is as follows: The African American Cultural Center at Indiana University of Pennsylvania (IUP) is dedicated to the enhancement of multicultural awareness and racial sensitivity. Through educational, cultural, and social activities and provision of a facility for informal exchange, the center strives to foster growth, development, awareness, and sensitivity among students, faculty, and staff. As the center presents interventions and programs that focus primarily upon African American history, culture, achievements, and contributions, the center will demonstrate cultural differences while promoting their understanding and appreciation. 6. The AACC is managed and led by a Director who reports to the Vice - President of IUP's Student Affairs Division. a. The AACC is housed under the Student Affairs Division. b. The AACC office is located on IUP's main (Indiana) campus. 7. The AACC provides a multitude of services, including but not limited to, the following: a. Assessing the interests of African - American students in educational and social programs, and responding to the extent that personnel, facilities, and resources permit; b. Providing and encouraging effective advisement of minority student organizations and individual students as needed; C. Assisting in the orientation of African American students to the culture of the institution, and providing support for those students as they progress through the university, d. Providing opportunities and support for African American and other minority students and organizations to develop and sponsor appropriate programs and to otherwise fully participate in the IUP curriculum; e. Providing training in leadership skills and other personal social skills for African American students, and supporting those seeking to assist them; Promoting and sponsoring events that focus on African American heritage and multicultural diversity; g. Serving as a supplement to classroom instruction as needed; h. Aiding in the facilitation of academic and multicultural programs and workshops for faculty, staff, and students that focus on: Awareness of cultural differences. 2. Self-assessment of cultural awareness and possible prejudices. 3. Changing prejudicial attitudes or behaviors. Princes, 16 -002 Page 4 Supporting the academic, student development, and programmatic goals of the offices of the Center for Student Life, Social Equity and Diversity, and Women's Studies; Systematically promoting the participation of African American and minority students for leadership roles in campus governance organizations; k. Encouraging and acknowledging outstanding accomplishments and contributions of African American students at IUP; Encouraging and participating in collaborative programming with African American groups and other minority and university organizations; M. Assisting with, identifying, and responding to the specific programmatic and academic needs of African American and minority students, making referrals to other university offices as appropriate; n. Providing mailboxes for a limited number of student organizations; o. Maintaining a library of African American cultural and educational resources (books, magazines, journals, videos, etc.); P. Maintaining meeting facilities to accommodate up to fifteen persons, lounging, and study facilities (TV, VCR, DVD, computers); q. Publishing a biannual calendar of events, newsletter, and webpage calendar; Promote and/or encourage African American, other minorities, and/or underrepresented students in community service activities; and S. Serve as a clearinghouse of information related to the success of African American or other minority and underrepresented students (e.g., Bulletin of Mobs, Scholarships, and Graduate School opportunities). 8. The AACC is a member of the national organization of the Association of Black Cultural Centers ("ABCC"). a. The ABCC seeks to celebrate, promote and critically examine the cultures (ways of life) of the following ethnic groups; African American, Latino, Asian American and Native American. b. The ABCC seeks to institutionalize those Centers, including Multicultural Centers, to enhance individual, community and global development. C. The ABCC believes an increased understanding of history and culture of each ethnic group will lead to authentic integration on campus and in the community. d. The ABCC consists of over 300 members. Membership in the ABCC provides a national network between Centers. 9. The Student Cooperative Association ( "Co -Op ") is a nonprofit 501c(3) tax - exempt entity that provides services, facilities, and activities for the purpose of enriching the quality of life for the IUP community. Princes, 16 -002 Page m a. The Co -Op's primary sources of funding are from IUP activity fees and revenue received through the operations of a college bookstore. b. The Co -Op does not receive any direct funding from the Commonwealth. 10. The Co -Op is governed by a Board of Directors (`Board ") that meets on a bi- weekly basis. a. The Board consists of IUP students, faculty, and alumni. A majority of the Board consists of students. b. For each meeting the Board receives a finance report and the prior meeting's minutes. Board members do not receive a list of bills to be paid. 11. The Co -Op's day -to -day operations are managed by a CEO /Executive Director (hereafter, "Co -Op Director') and staff. 12. The PASSHE Board of Governor's Policy 1985 -04 -A: University External Financial Support, requires a Memorandum of Understanding ( "MOU ") between IUP and the Co -Op to outline the respective roles between the entities. a. The MOUs detail that by May 1 sl of each year the Co -Op is to propose to IUP the appropriate student activity fee and related summary budget. b. IUP is to assess, collect, and remit the activity fee to the Co -Op. C. The Co -Op administers all monies received from student activity fees for the purpose of supporting student activities. d. The Co -Op is to provide sponsorship, funding, and management or coordination of selected student recreational and cultural programs. The Co -Op provides physical and financial support to over 100 student organizations, including the AACC. 13. In or around February of each year, Co- Op- funded student organizations submit a budget request to the Board for its reviewlapproval. a. The budget request identifies events /programming for the upcoming year. b. By July the Board is to approve the Co -Op's budget (July 15t-June 30th) that includes the allocation for each student organization. 14. Co -Op- sponsored student organizations receive funding from the Co -Op for student recreational and cultural programming. a. The student organization ma yy organize programming /events without the involvement of IUP or the Co -Op. 1. The programming /event must meet the mission of the student organization. 15. The student organization is to submit a payment request for programming /events along with any support documentation necessary, which may include a signed two party contract. Princes, 16 -002 59—e -6- a. Two party contracts may be arranged between the student organization and the vendor /contractor without the involvement of IUP or the Co -Op. b. Prior to the fall semester of 2015 the contracts were signed by a representative of the student organization on behalf of IUP. IUP has designated individuals who are authorized to exercise presidential contracting officer authority under the provisions of Act 57 of 1998 and Board of Governors Policy 1998 -04. 2. IUP was unaware that representatives of student organizations were signing contracts under the name of IUP without having the designated authority to do so. aa. IUP discovered the contracting discrepancy during the fall semester of 2015 and has since taken measures to ensure contracts are being signed by individuals that have been specifically delegated authority as contracting officer and fiscal officer. 16. The payment request and support documentation are reviewed /approved by the CEO /Executive Director before disbursement. a. The review is to ensure fiscal responsibility and to ensure that the event is aligned with the student organization's mission. b. The review does not include analysis or review for potential conflict -of- interest. 17. Once the request is approved by the CEO /Executive Director, payment is remitted to the respective vendor/contractor. a. The CEO /Executive Director has the ability to present questionable payments to the Co -Op Finance Committee for payment authorization. b. Approved payments are forwarded to the Co -Op Secretary/Treasurer for the signing of Co -Op checks. 18. As Director, Princes` job duties /responsibilities included, but were not limited to, the following: a. Leadership Serving as a member of the Student Affairs Leadership Team; 2. Conducting training on cultural awareness and diversity for student organizations, IUP faculty /staff, and community members; 3. Serving as the Student Affairs Division's liaison to the Office of Social Equity; 4. Positioning the AACC's image and mission as an active, visible, intellectual, educational, and cultural facility. b. Programming and Community Engagement 1. Develop and deliver educational, social, and cultural programs; Princes, 16 -002 app 2. Deliver student programming and assess the achievement of the student learning outcomes, participation, and satisfaction; 3. Contribute to IUP and community efforts to develop strong IUP/community relationships and work collaboratively in development of IUP and community activities to observe ethnic and cultural traditions. C. Advocacy and Student Leadership Development 1. Develop a variety of educational, cultural, and social programs, which includes lectures, exhibits, or social activities; 2. Serve as an advocate and resource person for students of color and effectively facilitate formal and informal student engagement and advocacy; 3. Develop and contribute to co- curriculum -based learning; 4. Develop divisional programs which actively engage students in relevant IUP and community experiences; 5. Work with other IUP entities to provide mentoring or other outreach support; 6. Support IUP enrollment management. d. Center Administration 1. Direct, plan, and implement operational plans; 2. Hire, train, and supervise clerical support staff, student work -study employees, and student programmers; 3. Manage financial and physical plant resources; 4. Provide accessibility and a welcoming environment for IUP and the community; 5. Conduct assessments and complete an annual report of accomplishments and respond to on -going requests for data and information. e. Other Duties 1. Perform other duties as assigned by the Vice President of Student Affairs. 19. From at least February 2006 to June 2015, Princes reported directly to Dr. Rhonda Luckey, Vice - President of Student Affairs. a. Luckey met with Princes regularly to discuss and offer guidance to AACC programing /events. 1. The detail of the conversations varied in content and scope. Princes, 16 -002 a�F 2. Princes was not required to obtain prior authorization from Luckey to arrange /schedule AACC programslevents. aa. Princes kept Luckey abreast of AACC programming /events. bb. The time and detail spent discussing program /event depended largely on its intricacy and costs. 20. IUP issues employees Bank of America travel cards to be used for business - related travel expenses. a. Each month IUP employees submit a travel card transaction log, statement of account portrait, andlor receipts of their expenses, along with their Bank of America statement reflecting card activity. 1. The documentation is audited by IUP's Finance Department. 2. The documentation includes the employee signature and the signature of their supervisor. b. IUP makes payment to Bank of America directly via wire transfer based on the total of all employee travel card expenses for the month. C. As Director, Princes was issued Bank of America travel card no. [number redacted]. THE FOLLOWING FINDINGS ARE IN RELATION TO PRINCES CONTRACTING WITH HER BROTHER'S MUSIC GROUP, THE MISTERY BAND, TO PERFORM AT A 2 013 NAACP BANQUET. 21. The NAACP is the nation's oldest, largest, and most widely recognized grassroots- based civil rights organization with membership of approximately one half million members and supporters throughout the United States and the world. a. The NAACP advocates for civil rights in communities, campaigns for equal opportunity, and conducts voter mobilization. 22. The NAACP maintains chapters in Indiana, Pennsylvania, and at IUP. a. Both the NAACP -IUP Chapter and the NAACP - Indiana Chapter sponsor events including fundraisers, banquets, and speaking engagements in or around Indiana, Pennsylvania, and on the IUP campus. At times the NAACP -IUP Chapter and NAACP - Indiana Chapter co- sponsored events. 23. Princes has been a member of the NAACP since her time in high school. a. Princes has been a paying member of the NAACP- Indiana Chapter since at least March 2012. Princes became Interim President of the NAACP - Indiana Chapter in or around March 2012. 2. Princes was elected President of the NAACP - Indiana Chapter in November 2012 and has remained in said position since that time. Princes, 16 -002 a�3 3. Princes was an advisor, in part due to her position as the Director, to the NAACP- Indiana Chapter for several years during her tenure. aa. Princes was the NAACP - Indiana Chapter co- advisor from 2014 until April 2016. 24. The AACC regularly collaborated with and/or attended NAACP - Indiana Chapter and NAACP -IUP Chapter events. a. The mission of the AACC and NAACP are similar in regard to promoting racial sensitivity and diversity through educational, cultural, and social activities. 25. The NAACP - Indiana Chapter holds an annual Freedom Fund Banquet for the purpose of inspiring, motivating, uniting, and educating, as well as providing opportunities to ... support the NAACP's mission. a. The banquet has music/entertainment provided by a music group. The music/entertainment is provided to the NAACP free -of- charge. 26. Leading up to the fall of 2013, the NAACP -- Indiana Chapter was seeking music/entertainment for the 2013 Freedom Fund Banquet. a. Princes informed the NAACP - Indiana Chapter that she could arrange forthe Mistery Band to perform at the banquet free -of- charge. 1. Prince's brother and member of her immediate family, Danny Wilbon, is a member of the Mistery Band. 2. The Mistery Band was formed and performs in the Chicago, Illinois, area. b. NAACP members were receptive to Princes' offer. 27. Princes contacted Mistery Band member Clayborn Williams to arrange the performance at the 2013 NAACP Freedom Fund Banquet. a. Princes offered to pay for the band's travel, lodging, and meal expenses. b. Princes did not offer to compensate the band for its performance. C. Williams accepted Princes' invitation to perform at the banquet. 28. On October 8, 2013, Princes, on behalf of the IUP -AACC, entered into an Engagement Agreement with Mistery Band Manager Clayborn Williams, "as the Authorized Representative" for the Mastery Band, for a musical performance on November 9, 2013, at 5:30 p.m. at the location of 1395 Wayne Ave. (Holiday Inn), Indiana, PA. a. The agreement delineated the AACC was to be responsible for the band's travel and lodging expenses, as follows: A $200.00 deposit and another $200.00 payment at completion of services for transportation costs; 2. Arrange van rental for the band; Princes, 16 -002 -ge TO 3. Provide three hotel rooms for the band members (Clay Williams, Ms. Eslavia Garza, Eamonn Prixy, Keenan Peason, Edgar Ricco, Danny Wilbon, and George Henderson); and aa. Lodging was listed at the Quality Inn, located at 1544 Wayne Avenue, Indiana, PA 15701. 4. Provide meals for band members as follows: Friday- Dinner; Saturday - Breakfast, Lunch, and Dinner; Sunday - Breakfast. b. The agreement did not specify that the performance was to be held at an NAACP banquet. C. The agreement was signed by Princes and Williams, dated October 29, 2013. d. Princes entered into the contract without informing Luckey or any other UP official of her familial relationship with Mistery Band member Danny Wilbon. 29. Princes' actions in contracting with the Mistery Band were within the duties /responsibilities of her position as Director. a. Princes' duties/responsibilities included collaborating with a community organization and developing a program that delivers an educational, social, and cultural program to the IN community. 30. On or about October 29, 2013, Princes submitted a payment request to the Co -Op requesting the payment amount of $750.00 for payment of travel and meal expenses for the Mistery Band. a. The description on the request was as follows: Perform on 11/9113 at the Annual NAACP Freedom Fund Banquet: Expenses: Travel - gasoline tolls $400 Meals -7 persons @$350 Please Provide separate checks as shown at amount. 1.$200 2.$200 3.$350 Total: $750 b. Princes signed the request, which bore the date of October 8, 2013. 31. Co -Op CEO /Executive Director Dennis Hulings was reluctant to approve Princes' payment request due to the concern that the event was a community organization sponsored event. a. In a November 5, 2013, email to Princes, Hulings' expressed apprehension that her request was for a community organization sponsored event. b. Hulings offered that the matter would be addressed by the Co -Op Finance Committee. C. In the email, Hulings indicated that the Co -Op had provided funding to the AACC in the past to send students to the NAACP banquet. Pa�� 16 -002 32. At the November 7, 2013, Co -Op Finance Committee meetin , Hulings presented Princes' request to pay for the band to perform at the NAAV banquet. a. Hulings explained that the music entertainment was for an event sponsored by a community organization at a location off - campus. b. At the meeting Princes informed the Committee that this was an AACC scheduled event and that 40 -50 students would be attending. C. The Committee approved the request via unanimous vote. 33. Princes did not disclose to the Committee her association with the NAACP or that her brother, Danny Wilbon, was a member of the band that was set to perform at the NAACP banquet at the time Co-Op officials were questioning the legitimacy of her payment request. 34. On or around November 7, 2013, the Co -Op remitted three checks to the Mistery Band c/o Clayborn Williams: Date Check Amount Vendor Co -Op Signatures Negotiated Date Negotiated _TT- 7- 7 3 200.00 Mistery Ban d (Ist Payrnent_ UP, a orn Williams 11-13-13 T-77 507 4 200.00 Mistery Band (2nd Payment P, EW ay orn Wiiliams 11-13-1 _TT-_7_-T3__ 1 507 5 350.00 Mistery Ban d (3rd PayrnentF CP, EW Ma--y-born Wiffiarns 11-13-13 Initials: DB -Dan Bawors, GP -Chuck Potthast, Go -Up Business Manager, EW -Ethan Wang, Go -Up _I_ reasurer a. On or about November 13, 2013, Williams negotiated the checks. 35. The NAACP - Indiana Chapter held its 27th Annual Freedom Fund Banquet on November 9, 2013, at the Holiday Inn, located at 1395 Wayne Avenue, Indiana, PA 15701. a. Princes attended the banquet pursuant to her affiliation with the NAACP and AACC. b. IUP students (some of which were associated with the AACC) attended the banquet. 36. During the banquet it became known through casual conversation that a member of the Mistery Band was Princes' brother. a. No issues were raised by any IUP or Co -Op officials about Princes' brother being a member of the band. 37. Princes submitted a travel card transaction log that covered expenses incurred from her IUP travel account no. [account number redacted] for the time period of October 28, 2013, to November 27, 2013. a. The log included meal expenses incurred on November 9, 2013, at Eat'n'Park restaurant, located at Indiana, Pennsylvania, in the total amount of $104.23 charged by Princes for meals for the Mistery Band. b. The log was not dated. 38. The IUP travel account no. [account number redacted] maintained a balance of $70,097.78 as of November 27, 2013. Princes, 16 -002 ap ge T2 a. $104.23 of the $70,097.78 was the Eat'n'Park meal expenses authorized by Princes (account no. [account number redacted]) for the Mistery Band. b. On or about December 12, 2013, lUP made payment from its JP Morgan Chase corporate checking account no. [account number redacted] to Bank of America in the amount of $70,097.78. 39. On or about February 12, 2014, Princes submitted a Travel Card Missing Receipt form to the lUP Finance Department relating to the November 9, 2013, Eat'n'Park meal expense. a. The form described the purchase and purpose as follows: Meals for performers of Mistery Band on 1119113 at NAACP Freedom Fund Banquet" 7- persons Total: $104.23 b. The form was signed by Princes, dated February 12, 2014, and b the Supervisor /Financial Manager dated February 15, 2014 (illegible signature). 40. On or by March 19, 2014, Princes and Susan Buffone, [UP Purchasing Department (part of the Finance Department), communicated about the November 9, 2013, Eat'n'Park meal expense. a. Per Buffone's request, Princes provided the names of the Mistery Band members and attendees of the Eat'n'Park meal. Princes provided the names identifying Wilbon as the band's "Road Manager." 2. Princes did not disclose her familial relationship with Wilbon to Buffone. 41. On or about January 30, 2014, the IUP Accounts Payable/Travel Office (part of Finance Department) received Enterprise Rent -A -Car invoice no. 9500005 3157, dated November 11, 2013, in the amount of $339.59. a. The invoice was for the rental vehicle used by the Mistery Band to travel from Chicago, Illinois, to Indiana, Pennsylvania, from November 8, 2013, to November 11, 2013, in order to perform at the 2013 NAACP Freedom Fund Banquet. b. The invoice listed Claiborne Williams and Danny Wilbon as drivers of the rental vehicle. 42. On February 21, 2014, Princes emailed the lUP Accounts Payable/Travel Office to authorize the payment to Enterprise Rent -A -Car. a. Princes explained that the travel expense was for the Mistery Band's performance at the November 9, 2013, NAACP Freedom Fund Banquet that was cosponsored by the AACC. b. Princes did not identify having a familial relationship with any of the band members or drivers of the vehicle. Princes, 16 -002 Page 3 43. IUP remitted payment via check no. 1000213011, dated February 21, 2014, to Enterprise Rent -A -Car in the amount of $1,269.39. a. $339.59 of the $1,269.39 payment was responsive to Enterprise Rent -A -Car invoice no. 950000533157. 44. On or about February 17, 2014, Princes learned through communication with the Co -Op and /or the Quality Inn Suites that the Quality Inn Suites erroneously charged the AACC's Co -Op account for the lodging of the Mistery Band. 45. On February 16, 2014, Princes charged her IUP travel card (account no. account number redacted]) the total amount of $566.04 to the Quality Inn Suites Indiana, Pennsylvania) for the hotel expenses incurred by the Mistery Band members. a. After making the payment, Princes submitted to the Finance Department a travel card transaction log that included expenses incurred from IUP travel account no. [account number redacted] for the time period of January 28, 2014, to February 27, 2014. b. The only item listed on the log was the Mistery Band's lodging expense. 1. The log listed the band members, including Danny Wilbon. 2. Princes did not identify on the log her familial relationship with Wilbon. 46. The IUP travel account no. [account number redacted] maintained a balance of $52,032.79 as of February 27, 2014. a. $566.04 of the $52,032.79 was associated with the three $188.68 payments to the Quality Inn Suites (Indiana, Pennsylvania) that was authorized by Princes for the lodging of the Mistery Band members. b. On or about March 13, 2014, IUP made payment to JP Morgan in the amount of $52,032.79 47. Princes submitted a Statement of Account to IUP that reflected expenses for the time period of January 28, 2014, to February 27, 2014. a. The Statement of Account documented the expenses of the three hotel rooms totaling $566.04. b. The Statement of Account was signed by Princes, dated May 13, 2014, and Luckey, dated May 14, 2014. 48. Princes submitted a memo, dated May 22, 2014, to Susan Buffone, IUP Purchasing Department, explaining that the Mistery Band performed on November 9, 2013, at the Holiday Inn for [UP --AACC and that the band's lodging expenses were mistakenly charged to the AACC Co -Op account. a. In the memo, Princes explained that as of February 17, 2014, the Quality Inn Suites had not been paid, therefore, she authorized payment through her IUP travel card. b. Attached to Princes' memo was a credit card authorization form from Princes to the Quality Inn permitting the $566.04 charge to Princes' IUP travel card. 1. The authorization form lists the Mistery Band members, specifically Danny Wilbon. Princes, 16 -002 Page 1 49. IUP made payments totaling $1,009.86 for the Mistery Band's lodging, travel, and meal expenses relating to its performance at the 2013 NAACP Freedom Fund Banquet above and beyond check nos. 0713, 50714, and 50715 previously issued as shown below: a. The expenses were a direct result of Princes contracting with the Mistery Band to perform at the 2013 NAACP Freedom Fund Banquet. 1. Princes arranged and/or authorized the vehicle rental, lodging, and meal expenses. 50. Princes arranged the performance of the Mistery Band at the 2013 NAACP - Indiana Chapter Freedom Fund Banquet, which resulted in IUP and the Co -Op remitting payments totaling $1,756.86 to facilitate the band's meal, travel, and lodging expenses. a. Princes became aware of the NAACP - Indiana County's need for a music group as a result of her officer position with the NAACP. b. Princes was familiar with the Mistery Band as a result of her brother's affiliation with the band. C. Princes contacted the Mistery Band to perform at the banquet and subsequently executed a performance contract, on behalf of IUP -AACC, to secure its services without prior review or authorization from IUP or Co -Op officials. d. Princes' actions in facilitating the performance resulted in lUP making payments totaling $1,009.86 for the band's meal, vehicle rental, and lodging expenses. e. Princes' actions in facilitating the band's performance resulted in the Co -Op making payments directly to the Mistery Band totaling $750.00. f. Princes failed to disclose her familial relationship with a member of the Mistery Band to IUP or Co -Op officials prior to contracting with the band and at the time Co -Op officials questioned the legitimacy of her payment request. THE FOLLOWING FINDINGS ARE IN RELATION TO PRINCES ENTERING INTO A CONTRACT ON BEHALF OF IUP WITH PRINCE MANAGEMENT GROUP, A BUSINESS WITH WHICH HER SON IS ASSOCIATED, 51. The AACC employs raduate assistants ( "GAs ") and undergraduate ( "UG ") student workers to assist in iTs day -to -day operations. a. Friends of the GAs and UGs also volunteered or gathered in the AACC office between classes. Princes, 16-002 p 9 52. Princes assigned GAs the responsibility of arranging /coordinating programs, including organized social gatherings, pre - commencement ceremonies, speaking engagements, etc. a. The GAs worked collaboratively on the programs with the guidance from Princes. 53. The GAs were tasked to provide Princes with a planning package for events, which included estimated costs, number of volunteers needed, possible cosponsors, advertising /marketing strategy, etc. a. Princes was responsible for contracting with agencies to book acts. 1. Princes either made the arrangements herself or delegated the work to her Administrative Assistant, Mary Elko. b. The AACC utilized the services of booking agencies to secure acts /entertainers and functions /events, including: The Talent Network, The Klages Agency, American Program Bureau, Rap Sessions, I.L.C., Sphinx Management Group, Novelty Entertainment, and Paradigm Attractions. 54. Princes held weekly staff meetings with the GAs on Wednesday mornings to discuss the development of AACC programs and any other AACC-related business. a. The meetings were not open to the public. 1. UGs attended the meetings at times. b. Minutes were not taken for the meetings. C. AACC staff also held informal and/or impromptu meetings throughout the day. 55. Princes' son, Maine Prince (a /k/a Donald J. Princes), is an original incorporator, along with his spouse, Bria Prince, of the Philadelphia Sports Training Center and Philadelphia Sports Training Center, LLC. a. The companies were one and the same and shared the same purpose in providing sports management, consultation, and training services. b. The companies were in operation from at least 2006 until 2013. 56. By July 2014 Princes renamed Philadelphia Sports Training Center and /or created a new company named Prince Management Group (hereafter, "PMG "). a. The Department of State has no record of PMG being incorporated within the Commonwealth. b. PMG offers personal, business, and sports consultations as well as printing services. 57. On or about July 14, 2014, PMG opened business checking account no. [account number redacted] with TD Bank. a. Bank records reflect Prince /PMG as the sole proprietor of PMG. Princes, 16 -002 age 16 b. W -9 (Federal Tax ID form) and TD Bank records reflect Prince`s /PMG's address of [address redacted]. 58. By August 2014 the AACC was planning its annual school year kick -off event known as "Counterblast." a. While planning the event, GAs researched potential comedians to perform. Comedians /entertainers are regular performers at Counterblast events. 2. The research was done with no preference or influence from Princes. b. The GAs contacted several comedians to determine their interests, availability, and performance fees. One of the comedians contacted was Reginald "Bruh -Man" Ballard (hereafter, "Bruh- Man "). C, The GAs provided Princes with a program plan that included information regarding the potential booking of the Bruh -Man. 59. Princes contacted PrincelPMG with the expectation of booking the Bruh -Man for the 2014 Counterblast event. a. Princes contacted PrincelPMG based on the understanding that PrincelPMG worked in the entertainment industry with the capability of contacting /booking acts. b. Princes had not previously contacted PrincelPMG to book any acts in relation to UP. C. Princes did not contact any of the booking agencies previously utilized by the AACC for booking acts /entertainers. 1. PrincelPMG was the only contact made. 60. On or around the time Princes inquired with PrincelPMG about booking the Bruh - Man, PrincelPMG discussed with Princes her ability to solicit UP student organizations and/or colleagues to utilize PMG services. a. Emails between Princes and Prince /PMG on August 26, 2014, and August 27, 2014, discussed booking a show at IUP and soliciting other African American Centers for a fashion show program. 1. An August 26'h email from PrincelPMG to Princes provided information regarding a fashion show program. 2. An August 27th email from Princes to PrincelPMG confirmed she would forward the fashion show information to the [ABCC] (which includes over 300 schools) and that she was interested in booking the Bruh -Man. 61. Between August 29, 2014, and September 3, 2014, Princes and Prince /PMG exchanged emails for the purpose of booking the Bruh -Man for the 2014 Counterblast event. Princes, 16 -002 a7 a. The emails reflect alterations being made to the Bruh -Man agreement, travel plan arrangements, and Prince's /PMG's request for a pre -show deposit of 5 %. Princes was not able to agree to Prince's /PMG's request for a pre - show deposit, since such deposits are not offered to performers at IUP. 62. A Live Performance Agreement dated August 29, 2014, was entered into between Princes and Prince /PMG by email and/or fax for a 90- minute stand -up comedy show to be held on September 12, 2014, bythe Bruh -Man at IUP's HUB Delaware Room for the amount of $8,800.00 (hereafter, "Bruh -Man Agreement "). a. The Bruh -Man Agreement was signed by Princes, dated September 4, 2014, as Director of the IUP -AACC and by Prince, dated August 29, 2014, as Agent/Business Manager of PMG. 1. The agreement was not signed by a witness. b. The Bruh -Man Agreement was sent between Princes and Prince/PMG via Princes' IUP email and /or to the AACC by fax. C. Princes did not have any IUP officials review the contract. Princes generally did not have contracts she arranged for the AACC reviewed by IUP officials. 63. A Sales Agreement dated September 1, 2014 (invoice no. 02138) accompanied the Bruh -Man Agreement listing the following fees [charged] to the AACC: tvent [late on September 1z, 2U14 Appearance ree Acquiring comedians for a college entertainment event: Regmaid "Bruh -Man" Ballard CJ Burne Administrative _ Costs Booking a. The Sales Agreement was signed by Princes, dated September 4, 2014, and by Prince, dated September 1, 2014. 64. Princes' role in arranging the Bruh Man to perform at the 2014 Counterblast event was within the duties responsibilities of her position as Director. 65. A September 3, 2014, social media post on PMG's Facebook page announced the signing of the Bruh -Man for an unnamed upcoming event. 66. On or about September 4, 2014, Princes, in her public position, submitted a Payment Request to the Co -O for the payment of $8,800.00 to PMG in relation to the scheduled performance of the Bruh -Man at the 2014 Counterblast event. a. Princes signed the request as the advisor of the AACC. b. The request was initialed by Hulings, signifying the approval of the request. Princes, 16 -002 a18 C. Signed copies of the Bruh -Man Agreement, Sales Agreement, and PMG's W -9 (Request for Taxpayer Id Number and Certification) were attached to the request. 67. On September 4, 2014, Princes booked a flight for the Bruh -Man through Travelocity.com (Travelocity Itinerary No. 17495412780) for the comedian's performance at the 2014 Counterblast event. a. The flight was scheduled to depart Los Angeles, California, for Pittsburgh, Pennsylvania, on September 11th and return to Los Angeles, California, on September 13th. b. The cost for the airline ticket was $561.20. C. Princes made payment to Travelocity through the use of her IUP travel card account no. [account number redacted] in the total amount of $561.20. 68. On September 7, 2014, Princes cancelled the Bruh -Man's reservation (Travelocity Itinerary No. 17495412780) and booked a new flight with Travelocity with a new departure date of September 12th. a. The fligght was to depart Los Angeles, California, on September 12th and return to Los Angeles, California, on September 13th. b. The cost of the airline ticket was $761.20 ($741.20- airline ticket and $20- booking fee). C. Princes made payment using her IUP travel card.). 69. Princes submitted a travel card transaction log listing the expenses incurred from her IUP travel account no. [account number redacted for the time period of August 28, 2014, to September 26, 2014. a. The to itemized the airline ticket expenses for the Bruh -Man totaling $761.20. 1. The cancelled airline ticket, in the amount of $561.20, was also noted on the log. 70. The IUP travel account no. [account number redacted] maintained a balance of $43,694.52 as of September 26, 2014. a. $761.20 of the $43,694.52 was associated with the flight expenses for the Bruh Man which was authorized by Princes. b. On or about October 10, 2014, IUP made payment to JP Morgan in the amount of $43,694.52. 71. For IUP procurement purposes, Princes submitted a Statement of Account to IUP that noted her expenses for the time period of August 28, 2014, to September 26, 2014. a. The Statement of Account documents the expenses of the Bruh Man's airfare in the amount of $761.20. b. The Statement of Account was signed by Princes, dated November 19, 2014, and Luckey, dated November 21, 2014. Princes 16 -002 aP ge_6 72. The Co-Op remitted check no. 109566, dated September 11, 2014, to PMG in the amount of $8,800.00. a. The check payment was issued in response to the Payment Request submitted by Princes. b. The check was signed by Co -Op representatives Chuck Potthast and James Smith. 73. The AACC's 2014 Counterblast event was held on September 12, 2014, at the Co- Op's HUB Delaware Room and Outdoor Area. a. The program was open to IUP students, staff, and faculty as well as community members. 1. There was no admission fee to attend the event. 74. The Bruh -Man performed at the 2014 Counterblast event held on September 12, 2014. a. Princes and Prince /PMG attended the event. 75. A September 12, 2014, social media post on PMG's Facebook page reflected a picture of Princes and PrincelPMG and identified Princes as Maine Prince's mother: "My beautiful mother Dr. Carolyn Princes ... she put on a great event and I was happy that I could be part of the festivities in bringing my client Reggie Ballard "Bruh -Man" to perform for the students" 76. A September 15, 2014, social media post on the IUP- AACC's Facebook page reflected [a] picture of Princes, Maine Prince, Bruh -Man, and Aaron Princes (another son of Princes). a. On September 23, 2015, Princes commented on the post thanking PrincelPMG: "My gifts from God with comedian Bruh Man! Thanks son." 77. Princes accepted Co -Op check no. 109566 from the Co -Op and delivered the check to PrincelPMG. a. On or about September 15, 2014, check no. 109566 was deposited into PMG's TD Bank business account. 1. PrincelPMG endorsed the backside of the check. 78. On September 16, 2014, PrincelPMG withdrew $800.00 cash from PMG's TD Bank business account. a. The withdrawal slip reflected Prince's /PMG's re uestforthe disbursement of four (4) $100.00s, ten (10) $20.00s, and four (4) $ 50.00s. 79. On or about September 19, 2014, PrincelPMG made payment to Princes for reimbursement of the Bruh Man's travel expenses. a. PrincelPMG remitted from PMG's TD Bank business account check no. 0099, dated September 19, 2014, in the amount of $992.20 to Princes for the reimbursement of the Bruh -Man's travel expenses. Princes, 16 -002 alp ge TO The check memo listed "Comedy Show Travel." 2. The reverse side of the check was signed by Princes. b. The amount of $992.20 was paid out of PMG's account on the posting date of September 19, 2014. 80. The Bruh -Man Agreement sets forth that the University was to cover travel expenses and that such expenses had been deducted from the total amount of the agreement. a. Princes paid for the Bruh -Man's flight to Pennsylvania for the AACC event using her IUP travel card, resulting in IUP paying a total of $761.20. b. Princes accepted Prince /PMG check no. 099 even though the Bruh -Man's flight expenses were paid for by IUP, in accordance with the Bruh -Man Agreement. 81. Princes generated personal check no. 310, dated May 29, 2015, in the amount of $761.20 to be paid to IUP -AACC. a. The check was to reimburse the Co -Op's AACC account for the Bruh -Man's flight expense. b. Princes lost or misplaced the check and it was never deposited to the ]UP- AACC account. 82. Princes ultimately submitted a letter, dated July 16, 2016, to Luckey, along with personal check no. 1828, for the purpose of reimbursing the Co -Op's AACC account for the Bruh -Man's flight expense. a. The letter explained that in September 2014, PrincelPMG made payment (check no. 099) to reimburse the IUP AACC accountforthe Bruh -Man's flight expense and that she (Princes) misplaced or lost her personal check no. 310 of May 29, 2015, to IUP for such expense. b. In the letter Princes apologized for the inadvertent delay or mistake and requested that the enclosed personal check be deposited' into the Co -Op's AACC account. C. Princes' personal check #1828, in the amount of $761.20, to IUP -AACC was enclosed with the letter. 1. IUP did not deposit check no. 1828 and same is now void due to time. d. The payment was made by Princes after she received notification from the Investigative Division of the State Ethics Commission of the current investigation. 83. The payment ($761.20 issued by Princes was less than the amount PrincelPMG remitted to Princes and the amount Princes remitted to IUP. 84. Princes explained in a letter, dated August 11, 2016, that the difference of $231.00 was related to the car rental expenses incurred by the Bruh -Man. a. No documentation is available to support Princes' explanation. Princes, 16 -002 a�21 85. On or about the time Princes expressed interest in booking the Bruh -Man, Prince /PMG sought Princes to book additional acts through her association with IUP and as the AACC Director. a. Emails exchanged between PrincelPMG and Princes from August 26, 2014, and August 27, 2014, reflect that PrincelPMG inquired with Princes to book a fashion show at IUP and to solicit other African American Centers for a fashion show program. 1. Princes replied, via email, to PrincelPMG inquiring about the fashion show and indicating she (Princes) would forward the fashion show information to the ABCC (over 300 schools). b. In a January 15, 2015, email, PrincelPMG asked Princes for money to fix his car and as an alternative, to book a live band for the AACC. 1. PrincelPMG offered Princes a cover band for approximately $10,000.00 to $15,000.00 and questioned if Princes "could get the students to approve a live band. 2. PrincelPMG offered the band as part of a Spring Break party for March 2015 or an End of the School Year Party with the available dates of January 23, February 20 and 27, March 13, April 10, or June 12, 3. No evidence was found to suggest that Princes solicited IUP organizations in relation to Prince s1PMG's request. C. PrincelPMG solicited Princes in a February 6, 2015, email seeking Princes to book the Bronx Obama Impersonator for IUP in the Spring of 2015 and to inquire with other students about booking the act for the Spring with the cost as follows: Internship- $8,000 Vice President - $15,000 Presidential- $35,000 Princes sent an email to IUP student Aysia Pierce, President of the Co-Op operated student organization, the Black Emphasis Committee ( "BEC "), asking if the group would be interested in booking the Bronx Obama Impersonator. aa. Pierce presented the BEC with information about the Bronx Obama Impersonator; however, the organization decided not to pursue the booking. bb. Pierce informed Princes that the BEC was not interested in booking the impersonator. cc. Princes did not inform Pierce of her familial relationship with the booking agent (PrincelPMG) for the impersonator. d. PrincelPMG did not secure any additional events with IUP student organizations despite the efforts made by Princes. 86. By the 2015 s�rin semester, Princes was involved in discussions with colleagues at IUP in relation o holding a teach -in panel discussion for the civil rights movie Selma. Princes, 16 -002 a a. Selma is a 2014 motion picture drama based on the 1955 Selma to Montgomery voting rights marches. b. Selma was released on December 25, 2014, and re- released on March 20, 2015, in honor of the 50th anniversary of the historical march. 87. Princes and AACC Administrative Assistant Mary Elko began efforts to secure Selma for an AACC sponsored teach -in panel discussion at IUP. a. Princes and Elko contacted area movie theaters as well as a Pittsburgh - based organization with the interest of obtaining the film to screen for the Indiana, Pennsylvania, community. b. Their initial efforts to secure the film were unsuccessful. 88. In February 2015 Princes emailed IUP representatives (department heads, faculty members) and community organization leaders about the AACC's intention to hold the Selma teach -in panel discussion. a. The email noted that Princes was waiting to hear from individuals in Pittsburgh about obtaining the film. b. The email noted that Princes was seeking to have the film screened as part of a community partnership with the AACC and the NAACP - Indiana County. 89. Princes contacted Prince /PMG to obtain Selma after efforts to secure the film herself were unsuccessful. a. Princes contacted PrincelPMG without being advised or directed by any IUP or AACC representative to do so. b. Princes did not inform any IUP or AACC representatives that she was seeking to obtain the film from PrincelPMG. 90. On or by February 25, 2015, PrincelPMG informed Princes he would able to obtain the film for the AACC. 91. On February 25, 2015, Princes emailed IUP representatives and local community organization leaders to inform them that the AACC was able to obtain Selma. a. The email noted that Princes expected the screening date to be March 31, 2015, at IUP's Fisher Auditorium. b. The email noted that Princes was seeking to have a separate morning screening for schoolchildren, as well as an evening session for IUP students, with panel discussions at both sessions. The AACC ultimately arranged three screenings as follows: • March 301h @7pm - public session, • March 315t @10am juniorlsenior high school, and • March 315t @6pm - college students /community. C. The email noted that there was to be no cost for attendees; however, attendees were required to obtain a ticket through an online system that had been devised to accomplish such. Princes, 16 -002 ageM d. The email noted that Princes was seeking sponsors for the event and currently had two sources of co- sponsorships, identified as the Frederick Douglas Institute and the IUP Admission Office. 92. On or about February 27, 2015, Princes entered into a Non - Disclosure Agreement between the AACC and PMG (as "Hosting Party ") and Maine Prince (as "Business Consultant "), Paramount Pictures (as "Disclosing Party "), and Criterion Pictures USA (as "Distributing Party "). a. The agreement detailed that the movie Selma was to be screened on campus on March 30, 2015, and March 31, 2015 (hereafter, "Selma Contract "). b. The Selma Contract was signed by Princes and Maine Prince, dated February 27, 2015. C. Princes did not have any IUP official review the contract. 93. A Sales Agreement (invoice no. 032165) accompanied the Selma Contract which itemized the expenses owed to Prince /PMG as follows: a. The Safes Agreement was signed by Princes and Prince/PMG, dated February 27, 2015. 94. Princes' involvement in coordinating the Selma event was within the duties/responsibilities of her position as Director. a. Princes' duties/responsibilities included collaborating with community organizations and developing a program that delivers an educational, social, and cultural program to the IUP community. 95. On or about February 27, 2015, Princes submitted a Payment Request to the Co- Op for the payment of $4,170.97 to be made to PMG for the Selma screenings. a. Princes signed the request as the advisor of the AACC. b. The request was initialed b Co -Op CEO /Director Louis Garzarelli signifying the approval of the request. G. Signed copies of the Selma Contract, Sales Agreement, and PMG's W -9 were attached to the request. 96. Princes and Prince/PMG discussed promotional work for the Selma event in the weeks leading up to the event. a. A March 20, 2015, email from Prince/PMG to Princes addressed a promotional design for the Selma screening. Princes, 16 -002 age 74 The email noted that Prince /PMG sought for the promotional design to be used in mass emails for the event and on social media to reflect the AACC's support for the screening. 2. The email included a link to the www.SELMAat[UP.com webpage as well as a Facebook event page for the event hftps://www.facebook.com/events/1 409069512738302/. b. Promotional information for the Selma event was posted on PMG's Facebook page on March 22, 2015, March 24, 2015, and March 31, 2015. The March 22, 2015, posting noted that PMG was co- hosting with IUP -AACC and the NAACP-Indiana County as an exclusive movie screening. 97. Luckey and Princes were in communication with each other in the weeks leading up to the Selma event. a. It was customary for Luckey and Princes to discuss potential and /or upcoming AACC programs /events. b. Princes advised Luckey of the budget and timing for the Selma event. C. Princes did not disclose that she would be signing a contract on behalf of UP in association with the event. d. Princes did not disclose that she would utilize the services of her son or his company to secure Selma for the event. 98. On or about March 20, 2015, Luckey contacted Princes about concerns with the event's advertising. a. Luckey's concerns were in relation to PMG and IUP websites being listed on advertisements for the event. Luckey advised Princes that all solicitation of gifts should be done through IUP - Advancement Office. b. Princes responded to Luckey's concerns by email on March 20, 2015, noting the following: 1. "Prince Management Group is the agency that got the film for me (after much disappointment from other sources) and indicated that they would help with promoting the even, including the design of the web page for the event[...] There is no charge for the tickets." 2. "My name is not associated with Prince Management Group, nor is my name Prince. As with all agencies through which the AACC 90 contract with for programs, the agency is a sponsor and will often use their name associated with our event." 3. "The agency [PMG] was to assist me with advertising, thus I asked them to send out notices to sponsors and /or supporters." 99. Princes never disclosed her familial relationship with Prince /PMG to Luckey or any other UP official at a time concerns were being raised about a perceived relationship to PMG. Princes, 16 -002 P ge L5 100. A March 22, [20151, social media post on the PMG Facebook page announced the collaboration of PMG, IUP -AACC, and NAACP - Indiana County for the Selma event. a. Additional posts about the Selma event were posted on March 24th, 27th, & 31St and April 1St 1. The April 1St post noted PMG as the Selma event coordinator. 2. None of the posts included information regarding Prince's /PMG's familial relationship with Princes. 101. The Selma event's program material identified the event as an AACC -- sponsored event in collaboration with the Indiana County NAACP, PMG, and support from numerous other IUP Departments and community agencies. a. The program material noted "a special thanks to PMG for assisti securing the film." b. The program material did not specify Princes having a familial relationship with Prince /PMG. 102. The Selma event was held as an IUP community event hosted by the AACC with numerous volunteers, aides, donors, staff and sponsors, including some of the following: • IUP Offices of Admissions, Society Equity, History, English, Student Affairs, and Film Studies • The College of Education and Educational Technology • The College of Humanities and Social Science • The President's Office • IUP student groups Flo'etry, Black Student League, and the Women's Volleyball Team « The Frederick Douglas Institute • Blairsville Underground Railroad • The League of Women Voters • First Commonwealth Bank • ARIN IU28 • Aramark Food, Inc. • Indiana School District • Armstrong School District • Homer Center School District • St. Joseph High School 103. A March 23, 2015, posting on the AACC website listed the Selma teach -in /panel discussion as a collaborative event between the AACC, the NAACP - Indiana Chapter, and PMG. a. PMG is listed as a management firm located in Philadelphia, PA. b. The post does not identify Princes having a familial relationship with Prince/PMG. 104. The Co -Op remitted check no. 111459, dated March 19, 2015, to PMG in the amount of $4,170.97 in association with the Selma event. a. The check payment was issued in response to the Payment Request submitted by Princes. b. The check was signed by Co -Op representatives Dan Bowers and James Smith. Princes, 16 -002 age T6 105. On or about March 31, 2015, check no. 111459 was deposited into PMG's TD Bank account. a. The reverse side of the check was endorsed by Prince. 106. The services of Prince /PMG were vital to the Selma event since Princes was unable to secure the film. a. PrincelPMG was used solely based on the actions of Princes in her capacity as a public employee. 107. Each year the AACC holds an End -of -Year Program to recognize and honor [persons] for their achievements, service to the AACC and/or IUP and/or contributions to social justice. a. The event includes a presentation of various recognition awards, including the People of the Year award. 1. The awards are selected by AACC staff, GAs, and /or the Awards Selection committee. aa. The Awards Selection committee is comprised of faculty, staff, and a community member. bb. A student's academic standings are also a determining factor in the selection process. b. Awardees are invited to the program and awarded with a certificate. 1. The AACC mails the certificate to those who do not attend the ceremony. C. A GA coordinates the award selection process. 1. Princes and the Awards Committee Chairman assist the GA with the presentation of awards. 108. As Director, Princes assists the Awards Committee in selecting award recipients by: a. Providing the Awards Committee with a list of nominees which [in 2015] included her son; b. Signing and overseeing the distribution of the letter of notice that solicited applicants and nominees; C. Ensuring he Awards Committee generates an inclusive list of potential candidates; d. Providing information on potential candidates; e. Supervising the GA who selected the recipients; f. Validating the final list of awardees with the Awards Committee Chairman. 109. The Awards Committee nominated PrincelPMG for the 2015 "Community Member" People of the Year award and PMG for the 2015 "Community Agency" People of the Year award. Princes, 16 -002 P ge�i a. As Director, Princes serves as an advisor to the Awards Committee. b. PrincelPMG was nominated by the Awards Committee in light of their involvement in securing Selma at a time the AACC was unable to otherwise secure the film. C. Once a decision was made as to the nominees, Princes confirmed with the Awards Committee that a consensus had been reached. 110. The 2015 End -of -Year Program was held on April 30, 2015, at the HUB Ohio Room. a. Prince was the recipient of the "Community Member" People of the Year award and PMG was the recipient of the "Community Agency" People of the Year award. 1. PrincelPMG did not attend the program. 2. The AACC mailed PrincelPMG the certificate due to his absence at the ceremony. b. Princes never disclosed her familial relationship with Prince /PMG to the Awards Committee. 111. On March 3, 2016, Princes was interviewed by representatives of the Investigative Division, during which Princes asserted, among other things, the following: a. Maine Prince is her son and his birth name was Donald Jermaine Princes. While in college Donald Jermaine Princes changed his name to Maine Prince. b. Princes denied having knowledge of Maine Prince's affiliation with PMG. c. Princes did not have lUP officials, including her immediate supervisor, review performance contracts or agreements she executed on behalf of the AACC nor was Princes ever directed to do so. d. Princes denied ever being educated on any conflict of interest policy. e. Princes made the final decision on the act/performer for AACC events /programs and normally was the individual who contacted a booking agent for the act/performer; however, there are times AACC student workers would research an act/performer. f. Princes admitted that Mistery Band member Danny Wilbon was her brother and that she initiated contact with the Mistery Band to perform at the NAACP Freedom Banquet in November 2013, since the AACC was a co- sponsor of the event and the event was in need of entertainment. 1. Princes claimed the band members were not compensated but that the band's travel, meals, vehicle rental, and hotel accommodations were paid for by the AACC. 2. Princes did not inform any IUP officials about contracting with a musical group in which her brother was a member; however, Princes claimed an announcement was made during the banquet identifying Wilbon as her brother. Princes, 16 -002 a�T8 g. Princes contacted Maine Prince about booking the Bruh Man in 2014 and that this was the first instance that she contacted Maine Prince, on behalf of the AACC, for business - specific purposes. h. Princes contacted Prince/PMG to obtain Selma for the AACC after the AACC and IUP faculty decided to hold a teach -in panel discussion for the film, and efforts to obtain the film by Princes and the AACC staff were unsuccessful. i. When questioned by Luckey in March 2015, Princes stated she was not associated with PMG. j. Princes contacted Maine Prince in the summer of 2015 after AACC student workers were unsuccessful in booking Owen for the AACC's 2015 Homecoming event. k. Princes directed Elko to instruct the AACC student workers to use the sponsorship kits to solicit funds for the Homecoming event and recommended having the sponsorship kits reviewed by IUP's Advancement Office. 1. Princes did not know if the sponsorship kits were brought to Advancement Office for review. I. Princes claimed to have no specific knowledge of the Ethics Act or that contracting with Maine Prince, PMG, or the Mistery Band may pose a potential violation of the Ethics Act. 1. Princes was familiar with the Ethics Commission in that she was required to file a Statement of Financial Interests form each year in her position as Director of the AACC. M. Princes claimed she contacted Maine Prince to book the aforementioned acts because he could obtain the acts at a cheaper rate than other agents. 112. In response to questions posed by the State Ethics Commission, Princes responded b letter dated August 29, 2016, in which she explained that Prince/PMG issued her check no. 0099, dated September 19, 2014, in the amount of $992.20, for the purpose of reimbursement for the Bruh -Man's travel expenses. a. Princes explained that she and Prince/PMG decided that the most expedient method to secure the Bruh -Man's travel at the time was for Princes to cover the Bruh -Man's travel expenses through her IUP travel card and for Prince/PMG to reimburse her the expenses at a later date. THE FOLLOWING FINDINGS ARE IN RELATION TO DISCREPANCIES FOUND ON PRINCES' CALENDAR YEAR 2010, 2011, 2012, 2013, AND 2014 STATEMENT OF FINANCIAL INTERESTS FORMS. 113. Section 1104(a) of the State Ethics Act sets forth that each public official of the Commonwealth shall file a Statement of Financial Interests for the preceding calendar year with the Commission no later than May 1 of each year that he holds such position and of the year after he leaves such position. a. Each public employee and public official of the Commonwealth shall file a statement of financial interests for the preceding calendar year with the department, agency, body or bureau in which he is employed or to which he Princes, 16 -002 Page 2 is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such position. b. Any other public employee or public official shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed or within which he is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. 114. Princes was required to file a Statement of Financial Interests ( "SFI ") for calendar years 2010 through 2014 as a public employee of IUP. 115. IUP's Human Resources Department sends emails to employees /officials identified as meeting the [Ethics Act's definition of the term "public official" or "public employee,] requesting the completion of an SFI form. a. Princes regularly received the email and completed an SFI b. The email indicates the recipient is to adhere to provisions of the State Ethics Act as follows: The Ethics Act prohibits public officials and public employees from engaging in activities that involve the use by a public official or public employee of his/her office or employment or any confidential information received through his/her holding public office or employment for the private pecuniary benefit of him /herself, a member of his /her immediate family, or a business with which he /she or a member of his /her family is associated 116. Each year IUP employees, including Princes, received an email from IUP's Human Resources Department informing them to comply with the Ethics Act and to complete their annual SFI. IUP did not provide Princes with any other training or instruction about her responsibilities or restrictions under the Ethics Act, including restrictions on entering into contracts with or for the benefit of immediate family members. a. The SFIs were to be submitted to the Department of Human Resources upon completion for filing purposes. 117. On January 19, 2016, Princes' SFI forms for calendar years 2007 to 2014 were received at the State Ethics Commission Central Office. 118. Discrepancies on Princes' SFIs for calendar years 2010, 2011, 2012, 2013, and 2014 were found as a result of the review. a. Block 10 requires the disclosure of all direct or indirect sources of income. Princes' SFIs for calendar years 2010 to 2014 failed to disclose income received from IUP. b. Block 13 requires the disclosure of any office, directorship, or employment in any business, including non - profit businesses. Princes' SFIs for calendar years 2012 and 2014 fail to identify her office as President of the Indiana Chapter of the [NAACP]. 119. As the Inclusion and Multicultural Pro ggramming S ecialist, serving as the Director of the AACC, for IUP, Carolyn Princes (Respondentfutilized the authority of her public Princes, 16 -002 a�310 employment for the private pecuniary benefit of herself, member(s) of her immediate family, and/or businesses with which she and/or members of her immediate family are associated, when she: a. Awarded, entered and /or attempted to enter into contracts between IUP /AACC and Danny Wilbon (brother) and/or the Mistery Band, as well as IUP /AACC and Maine Prince (son) and/or Prince Management Group (PMG), for acts /performances of various entertainment venues, including, but not limited to: The Mistery Band; the Bruh Man, and screening of the motion picture Selma. b. When Respondent awardedlentered into contracts /agreements between IUP /AACC and Maine Prince (son) and/or Prince Management Group (PMG), absent an open and public process. C. When she failed to disclose all reportable sources of income upon SFIs fled for calendar years 2010, 2011, 2012, 2013, and 2014 — namely income received from IUP. d. When she failed to disclose all reportable offices, directorships and/or employment in any business entity — namely her office of President in the Indiana, Pennsylvania, chapter of the NAACP upon SFIs filed for the 2012 and 2014 calendar years. III. DISCUSSION: As the Inclusion and Multicultural Programming Specialist, serving as the Director of the African American Cultural Center ( "AACC "), for the Indiana University of Pennsylvania ( "IUP "), Respondent Carolyn Princes, also referred to herein as "Respondent," ` Respondent Princes," and "Princes," has been a public official /public employee subject to the provisions of the Public Official and Employee Ethics Act ("Ethics Act "), 65 Pa.C.S. § 1101 et se . The allegations are that Princes violated Sections 1103(a), 1103(, 11050, , 11050M, and 1105 b)(8) of the Ethics Act, 65 Pa.C.S. §§ 1103(a), 1103(), 1105 a , 1105 , and 1105()(8): (1) When she utilized the authority of her public employment position for the private pecuniary benefit of herself, a member of her immediate family (namely her son, Maine Prince), and/or a business with which she /immediate family is associated (namely Prince Management Groupp (, "PMG ")), when she awarded and/or entered into contracts between IU[ ),"PMG")), and Maine Prince /Prince Management Group (PMG); (2) When she utilized the authority of her public position to award and/or enter into contracts valued in excess of $500.00, between IUP /AACC and Maine Prince/Prince Management Group (PMG), a business with which her son and member of her immediate family is associated, absent an open and public process; (3) When she utilized the authority of her public employment position for the private pecuniary benefit of herself, a member of her immediate family (namely her brother, Danny Wilbon), and/or a business with which she/immediate family is associated (namely "The Mistery Band °� when she awarded and/or entered into contracts between IUP /AACC and he Mistery Band; Princes 16 -002 app) (4) When, as the Inclusion and Multicultural Programming Specialist/Director of the AACC, she failed to identif all reportable sources of income on Statements of Financial Interests "SFIs" filed in connection with her public employment, for calendar years 2 10, 2011, 2012, 2013, and 2014; and (5) When, as the Inclusion and Multicultural Programming Specialist/Director of the AACC, she failed to identify her office, directorship and /or employment, narri her office of President held with the Indiana, Pennsylvania, Chapter of the NAACP, on SFIs filed in connection with her public employment, for calendar years 2012 and 2014. Per the Consent Agreement, it appears that the Investigative Division in the exercise of its prosecutorial discretion has elected to non pros the allegation in paragraph number 3 above involving Respondent's brother, Danny Wilbon, and The Mistery Band, as well as the alleged violation of Section 1105(a) of the Ethics Act. We therefore need not address those particular allegations. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private , pecuniary benefit of the public official /public employee himself, an member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1103(f) of the Ethics Act imposes certain restrictions as to contracting: § 1103. Restricted activities Princes, 16 -002 al' ge 2 (f) Contract, —No public official or public employee or his spouse or child or any business in which the person or his spouse or child is associated shall enter into any contract valued at $500 or more with the governmental body with which the public official or public employee is associated or any subcontract valued at $500 or more with any person who has been awarded a contract with the governmental body with which the public official or public employee is associated, unless the contract has been awarded through an open and public process, including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. In such a case, the public official or public employee shall not have any supervisory or overall responsibility for the implementation or administration of the contract. Any contract or subcontract made in violation of this subsection shall be voidable by a court of competent jurisdiction if the suit is commenced within 90 days of the making of the contract or subcontract. 65 Pa.C.S. § 1103(f). Section 1103(f) of the Ethics Act provides in part that no public official/public employee or his spouse or child or business with which the public official/public employee or his spouse or child is associated may enter into a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official/public employee is associated unless the contract is awarded through an open and public process including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded. Section 1105(b ) of the Ethics Act and its subsections detail the financial disclosure that a person required to file the SFI form must provide. Subject to certain statutory exceptions not applicable to this matter, Section 11 05(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office, directorship or employment in any business entity. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties` Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. IUP is a member of the Pennsylvania State System of Higher Education, also referred to herein as "PASSHE." Respondent Princes was employed at lUP as the Director of the AACC from September 17, 1990, until April 15, 2016, and as the Inclusion and Multicultural Programming Specialist - Cultural Center Director ( "Director ") commencing effective July 1, 2013. From at least February 2006 to June 2015, Respondent reported directly to Dr. Rhonda Luckey ( "Luckey "), Vice - President of Student Affairs. As Director, Princes' Job duties /responsibilities included, but were not limited to, developing and delivering educational, social, and cultural programs and contracting with agencies to book acts. Princes was not required to obtain prior authorization from Luckey to arrange /schedule AACC programs /events. Princes generally did not have contracts she arranged for the AACC reviewed by IUP officials. Princes, 16 -002 aP ge -3 As detailed below, during the relevant time pperiod, Princes used the authority of her public position to book a comedian, Reginald "Bruh-Man" Ballard (hereafter, "Bruh- Man "), for a 2014 AACC event and to arrange for the March 2015 screening of the civil rights movie, Selma, through her son's business. In August 2014 the AACC was planning its annual school year kick -off event known as "Counterblast." At that time, Princes' son, Maine Prince, owned a business named "Prince Management Group" (hereafter, "PMG "). Princes contracted with Prince/PMG to book the Bruh -Man for the 2014 Counterblast event. Princes' role in arranging the Bruh Man to perform at the 2014 Counterblast event was within her duties /responsibilities as Director. Princes and Prince/PMG entered into a "Live Performance Agreement" (hereafter, "Bruh -Man Agreement ") for the Bruh -Man to perform at IUP on September 12, 2014, for the amount of $8,800.00. The Bruh -Man Agreement was sent between Princes and Prince/PMG using Princes' IUP email and/or AACC fax. Princes did not have any IUP officials review the contract. The Bruh -Man Agreement was siggned by Princes as Director of the IUP -AACC, dated September 4, 2014, and by Prince asAgent/Business Manager of PMG, dated August 29, 2014. A Sales Agreement dated September 1, 2014, accompanied the Bruh -Man Agreement listing an appearance fee of $8,000.00 and a booking fee of $800.00. The Sales Agreement was signed by Princes dated September 4, 2014, and by Prince dated September 1, 2014. On or about September 4, 2014, Princes, in her public position, signed and submitted a Payment Request to a non - profit organization named the "Student Cooperative Association" ( "Co -Op ") for the payment of $8,800.00 to PMG in relation to the scheduled performance of the Bruh -Man at the 2014 Counterblast event. The Co -Op- -which is primarily funded through IUP activity fees and revenue received through the operations of a college bookstore -- supports student organizations. The Co -Op does not receive any direct funding from the Commonwealth. In response to the aforesaid Payment Request submitted by Princes, the Co-Op issued check no. 109566 dated September 11, 2014, to PMG in the amount of $8,800.00. The Bruh -Man performed at the 2014 Counterblast event held on September 12, 2014, and on or about September 15, 2014, Prince/PMG endorsed the reverse side of Co -Op check no. 109566 and deposited it into PMG's bank account. Per the Stipulated Findings, there may have been irregularities with the way the travel expenses for the Bruh -Man were handled. However, as such do not form the basis for the recommended technical violation of Section 1103(a) of the Ethics Act set forth in the parties' Consent Agreement, we need not further elaborate upon them. At or about the time Princes expressed interest in booking the Bruh -Man for the 2014 Counterblast event, Prince/PMG sought to book additional acts through Princes' association with IUP and her status as the AACC Director. By the 2015 spring semester, Princes was involved in discussions with colleagues at IUP in relation to holding a teach -in panel discussion for the civil rights movie, Selma. After efforts by Princes and an AACC Administrative Assistant to secure the Selma film were unsuccessful, Princes contacted Prince /PMG to obtain the film. Princes did not inform any IUP or AACC representatives that she was seeking to obtain the film from Prince/PMG. On or by February 25, 2015, Prince/PMG informed Princes he would able to obtain the film for the AACC. On or about February 27, 2015, Princes entered into a contract (hereafter, "Selma Contract" which included the AACC and PMG (as "Hosting Part IViaine Prince (as "Business Consultant "), Paramount Pictures, and Criterion Pictures USf�. Princes' involvement in coordinating the Selma event was within the duties /responsibilities Princes, 16 -002 aagge- 3-4 of her position as Director. Prince /PMG was used solely based on the actions of Princes in her capacity as a public employee. The Selma Contract detailed that the movie Selma was to be screened on campus on March 30, 2015, and March 31, 2015. The Selma Contract was siggned by Princes and Maine Prince, dated February 27, 2015. Princes did not have any IUP official review the contract. A Sales Agreement that accompanied the Selma Contract itemized the expenses owed to Prince /P G as totaling $4,170.97, including $3,500.00 for a screening fee, $350.00 for administrative costs/booking, and $320.97 for promotional flyers. The Sales Agreement was signed by Princes and costs/booking,, dated February 27, 2015. On or about February 27, 2015, Princes submitted a Payment Request to the Co -Op for the payment of $4,170.97 to be made to PMG for the Selma screenings. Princes signed the request as the advisor of the AACC. In response to Princes' aforesaid Payment Request, Co -Op check no. 111459, dated March 19, 2015, was issued to PMG in the amount of $4,170.97 in association with the Selma event. On or about March 20, 2015, Luckey contacted Princes with concerns about PMG and IUP websites being listed on advertisements for the event. Princes responded to Luckey's concerns by email on March 20, 2015, noting, inter alia: "My name is not associated with Prince Management Group, nor is my name rF' ince.'Fact Findin 98 b(2). Princes never disclosed her familial relationship with Prince/PMG to Luckey or any other IUP official at a time concerns were being raised about a perceived relationship to PMG. The Selma event's program material and a March 23, 2015, posting on the AACC website regarding the Selma event did not identify Princes having a familial relationship with Prince/PMG. There were three screenings of the Selma film on March 30-31, 2015. On or about March 31, 2015, Co -Op check no. 111459 was deposited into a PMG bank account. The reverse side of the check was endorsed by Prince. The parties have stipulated that as the Inclusion and Multicultural Programming Specialist, serving as the Director of the AACC, for IUP, Respondent utilized the authority of her public employment for the private pecuniary benefit of herself, member(s) of her immediate family, and/or businesses with which she and/or members of her immediate family are associated, when she awarded, entered and/or attempted to enter into contracts between IUPIAACC and Maine Prince and /or PMG for acts/performances of various entertainment venues, including, but not limited to, the Bruh Man and screening of the motion ppicture Selma. The parties have further stipulated that Respondent awardedlentered into contracts /agreements between IUPIAACC and Maine Prince and/or PMG absent an open and public process. With regard to Respondent Princes' SFIs, the parties have stipulated that Respondent failed to disclose IUP as a reportable source of income upon SFIs filed for calendar years 2010 through 2014 and also failed to disclose her office as President of the Indiana, Pennsylvania, chapter of the NAACP upon SFIs filed for the 2012 and 2014 calendar years. Having highligghted the Stipulated Findin .9s and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: 3. The Investigative Division will recommend the following in relation to the above allegations: Princes, 16 -002 a� That a technical violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Princes awarded and/or entered into contracts between IUPIAACC and Maine Prince/Prince Management Group (PMG), resulting in a private pecuniary benefit to Maine Prince (her son) and/or a business [with which] her son is associated (PMG). That a technical violation of Section 1103(f) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Princes awarded and/or entered into contracts between IUP /AACC and Maine Prince/Prince Management Group (PMG), absent an open and public process. C. That violations of Sections 1105(b)(5) and (8) of the Public Official and Employee EEthics Act, 65 Pa.C.S. & 1105(b))(5 ,(8), occurred when Princes failed to identify fU� as a source of income on Statements of Financial Interests filed for calendar years 2010, 2011, 2012, 2013, and 2014; and when Princes failed to identify her office as President of the Indiana Chapter of the NAACP for calendar years 2012 and 2014. Princes agrees to make payment in the amount of $3,000.00 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter or upon such reasonable schedule as Princes and the Commission may agree upon, with the stipulation that such schedule shall not extend beyond one year from issuance of the final adjudication. 5. Princes agrees to file complete and accurate amended Statements of Financial Interests with IUP through the Pennsylvania State Ethics Commission, for calendar years 2010, 2011, 2012, 2013, and 2014 within thirty (30) days of the issuance of the final adjudication in this matter. 6. Princes agrees to not accept any reimbursement, compensation or other payment from UP representing a full or partial reimbursement of the amount paid in settlement of this matter. i. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating apppropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Princes, 16 -002 alp ge T6 Consent Agreement, at 2 -3. We acceppt the parties' recommendations for finding technical violations of Sections 1103(a) and 1103( -) of the Ethics Act. The contracts that form the basis for finding these two technical violations are the Bruh -Man Agreement and the Selma Contract. Princes used the authority of her public position to direct both contracts to Maine Prince /PMG, absent an open and public process. Accordingly, we hold that a technical violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred when Princes awarded and/or entered into contracts between IUP /AACC and Maine Prince /Prince Management Group (PMG), resulting in a private pecuniary benefit to Maine Prince (her son) and/or a business with which her son is associated (PMG). We further hold that a technical violation of Section 1103(9 of the Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Princes awarded and /or entered into contracts between lUP /AACC and Maine Prince/Prince Management Group (PMG), absent an open and public process. We agree with the parties and we hold that violations of Sections 1105(b)(5) and of the Ethics Act, 65 Pa.C.S. § 1105(b)(5),(8), occurred when Princes failed to identify ID as a source of income on SFIs filed for calendar years 2010, 2011, 2012, 2013, and 2014; and when Princes failed to identify her office as President of the Indiana, Pennsylvania, Chapter of the NAACP for calendar years 2012 and 2014. As part of the Consent Agreement, Princes has agreed to make payment in the amount of $3,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter or upon such reasonable schhedule as Princes and the Commission may agree upon, with the stipulation that such schedule shall not extend beyond one year from issuance of the final adjudication. Princes has agreed to not accept any reimbursement, compensation or other payment from IUP representing a full or partial reimbursement of the amount paid in settlement of this matter. Princes has agreed to file complete and accurate amended SFIs with IUP, through this Commission, for calendar years 2010, 2011, 2012, 2013, and 2014 within thirty (30) days of the issuance of the final adjudication in this matter. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Respondent Princes is directed to make payment in the amount of $3,000.00 payable to the Commonwealth of Pennsylvania, with such payment forwarded to this Commission by no later than the thirtieth (301'') day after the mailing date of this adjudication and Order or upon such reasonable schedule as Princes and the Commission may agree upon, with the stipulation that such schedule shall not extend beyond one year from the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Respondent Princes is further directed to not accept any reimbursement, compensation or other payment from IUP representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent she has not already done so, Respondent Princes is directed to file complete and accurate amended SFIs with IUP, through this Commission, for calendar Princes, 16 -002 alp' ge 3 years 2010, 2011, 2012, 2013, and 2014 by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. As the Inclusion and Multicultural Programming Specialist, serving as the Director of the African American Cultural Center ( "AACC ), for the Indiana University of Pennsylvania ( "lUP "), Respondent Carolyn Princes ( "Princes ") has been a public official /public employee subJ'ect to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et .eg. 2. A technical violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. 1103(a), occurred when Princes awarded and/or entered into contracts between It P /AA C and Maine Prince/Prince Management Group ( "PMG "), resulting in a private pecuniary benefit to Maine Prince (her son) and/or a business with which her son is associated (PMG). 3. A technical violation of Section 1103(o of the Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Princes awarded and/or entered into contracts between IUPIAACC and Maine Prince/Prince Management Group (PMG), absent an open and public process. 4. Violations of Sections 1105(b)(5) and (8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5),(8), occurred when Princes failed to identify IUP as a source of income on Stattements of Financial Interests filed for calendar years 2010, 2011, 2012, 2013, and 2014; and when Princes failed to identify her office as President of the Indiana, Pennsylvania, Chapter of the NAACP for calendar years 2012 and 2014. In Re: Carolyn Princes, File Docket: 16 -002 Respondent Date Decided: 216119 Date Mailed: 2111119 ORDER NO. 1746 A technical violation of Section 1103(a) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1103(a), occurred when Carolyn Princes {Princes "), in her capacity as the Inclusion and Multicultural Programming Specialist, serving as the Director of the African American Cultural Center ( "AACC "), for the Indiana University of Pennsylvania ( "IUP'), awarded and/or entered into contracts between IUPIAACC and Maine Prince /Prince Management Group ( "PMG "), resulting in a private pecuniary benefit to Maine Prince (her son) and/or a business with which her son is associated (PMG). 2. A technical violation of Section 1103(f) of the Ethics Act, 65 Pa.C.S. § 1103(f), occurred when Princes awarded and/or entered into contracts between IUPIAA C and Maine Prince /Prince Management Group (PMG), absent an open and public process. 3. Violations of Sections 1105(b)(5) and (8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5),(8), occurred when Princes failed to identify IUP as a source of income on Stattements of Financial Interests filed for calendar years 2010, 2011, 2012, 2013, and 2014; and when Princes failed to identify her office as President of the Indiana, Pennsylvania, Chapter of the NAACP for calendar years 2012 and 2014. 4. Per the Consent Agreement of the parties, Princes is directed to make payment in the amount of $3,000.00 payable to the Commonwealth of Pennsylvania, with such Eforwarded to the Pennsylvania State Ethics Commission ( "Commission ") by no later than the thirtieth (30th) day after the mailing date of this Order or upon such reasonable schedule as Princes and the Commission may agree upon, with the stipulation that such schedule shall not extend beyond one year from the mailing date of this Order. 5. Per the Consent Agreement of the parties, Princes is further directed to not accept any reimbursement, compensation or other payment from IUP representing a full or partial reimbursement of the amount paid in settlement of this matter. 6. To the extent she has not already done so, Princes is directed to file complete and accurate amended Statements of Financial Interests with IUP, through this Commission, for calendar years 2010, 2011, 2012, 2013, and 2014 by no later than the thirtieth (30th) day after the mailing date of this Order. 7. Compliance with paragraphs 4, 5, and 6, of this Order will result in the closing of this case with no further action by this Commission. a. Non - compliance will result in the institution of an order enforcement action. BY THE COMMISSION, Nicholas • .