Conflict of Interest (COI)

Conflict of Interest

All university employees are required to disclose any actual, perceived, or potential conflicts of interest or commitment upon hire and annually thereafter. Employees must also promptly disclose any new actual, perceived, or potential conflicts of interest or commitment that arise throughout the year.

No university employee may use or attempt to use their university position, property, other resources, or position-based authority, to secure special privilege, benefit, or exemption for themselves.

All university employees must comply with documented management or mitigation requirements related to any real, perceived, or potential conflict disclosed.

After Disclosure

Upon receipt of a Conflict of Interest or Commitment Disclosure, the Office of General Counsel will review the disclosure to determine whether an actual, perceived, or potential conflict exists.

The Office of General Counsel will advise Human Resources of recommended mitigation, management, or monitoring measures. Human Resources will work with the employee and the employee’s manager to implement necessary measures.

If a mitigation plan is implemented, the employee is responsible for adhering to the plan. Should the conflict or circumstances related to the conflict change, the employee must notify their manager within 30 days so the mitigation plan can be reviewed and amended as necessary. The employees’ manager and Human Resources will maintain a copy of the mitigation plan for recordkeeping purposes. The employee's manager is responsible for monitoring compliance with the mitigation plan and following up with the employee as needed. Mitigation plans should be reviewed annually to ensure they remain appropriate and effective.