|Applies to:||Original Policy Date:||Date of Last Review:||Approved by:|
|All employees, excluding students||December 2014||August 2022||Dr. Marco Carvalho
Executive Vice President and Provost
This policy defines a conflict of interest or commitment and articulates an expectation for all employees to disclose real, perceived, and potential conflicts of interest or commitment. When possible new conflicts of interest or commitment should be disclosed prior to engaging in the activity that could be a conflict. The policy also establishes a procedure for the review and management of real, perceived, and potential conflicts of interest or commitment.
This policy applies to all university employees but excludes conflicts of interest related to funded research projects which are governed by the Conflict of Interest for Funded Research Projects policy.
All university employees are required to disclose any real, perceived, or potential conflict of interest or commitment to the university upon hire and then at minimum annually thereafter. Employees are required to disclose any new real, perceived, or potential conflicts of interest or commitment immediately 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.
New university employees receive the conflict of interest and commitment disclosure form through the HRIS. Employees are required to complete the form, which is saved in the HRIS.
All university employees will be provided the conflict of interest and commitment disclosure form through the HRIS annually. Employees are required to complete the form, which is saved in the HRIS.
In addition, all university employees are required to complete the conflict of interest and commitment disclosure form in the HRIS any time during the year when a real, perceived, or potential conflict of interest arises.
Employees should discuss new potential conflicts of interest or commitment with their supervisor or Human Resources as appropriate. This is particularly relevant when an employee may seek or receive an opportunity for additional employment outside of the university that may constitute a conflict of commitment.
If a conflict of interest or commitment is disclosed, the system will send the form to the Office of Compliance and Accreditation. The Office of Compliance and Accreditation will coordinate with the Office of Human Resources and the Office of the Provost as needed to review the real or potential conflict. The Office of Compliance and Accreditation will send the discloser an acknowledgement of the disclosure and any required steps to minimize the risk of the conflict.
A conflict of interest is a situation in which an individual’s financial, professional, or other personal consideration may directly or indirectly, or have the appearance of affecting, an individual’s professional judgement in exercising any University duty or responsibility.
A conflict of commitment is a situation where an individual engages in external activities, either paid or unpaid, that interfere with the individual’s primary obligation and commitment to the university.
Common Conflicts of Interest and Commitment
For reference, common conflicts of interest and commitment have been provided. Please note this list is not exhaustive but is provided as example of conflicts of interest and commitment.
- Financial interests
- An employee or member of their immediate family has direct or indirect financial interest in a company that does business with the university or competes with the university in doing business
- An employee has other employment or serves as a consultant for a company that the university may establish services with, and the employee is involved in the selection of the vendor
- An employee with decision making authority accepts a gift (non-trivial) from a vendor seeking to establish a relationship with the university
- Secondary employment
- An employee completes work for a secondary employer during university business hours or using university resources (including facilities, IT, etc.)
- An employee works for a secondary employer that seeks to do business with the university or in competition with the university
- An employee’s work for a secondary employer involves or results in frequent or extended absences from university duties
- An employee works for a secondary employer and references their affiliation with the university in that role
- Personal relationships
- An employee who has decision making authority related to hiring, participating in the hiring, evaluation, or termination of a family member or someone with whom the employee has a close personal relationship
- An employee who has decision making authority related to admissions or financial aid participating in decisions affecting admission or financial aid of a family member or someone with whom the employee has a close personal relationship
Secondary Employment means any external employment or work activity, or self-employment, that is in addition to an employee's position with the university, even while on leave. Secondary employment includes, but is not limited to, working for another employer, self-employment, the private practice of any profession, occupation or trade, consulting services, being involved in a family business, volunteer work and teaching.
All employees are responsible for disclosing all real, perceived, and potential conflicts of interest.
Human Resources and supervisors are responsible for consulting with employees regarding conflicts of interest.
The Office of Compliance and Accreditation, Human Resources, and the Office of the Provost are responsible for the review and acknowledgement of conflict of interest disclosures, including the establishment of management plans to mitigate risk associated with those conflicts.
Failure to disclose any real, perceived, or potential conflict of interest or commitment using the conflict of interest and commitment disclosure form or knowingly filing an incomplete, erroneous, or misleading form may result in disciplinary action up to and including termination.
Failure to adhere to any documented management instructions regarding the management or mitigation of the conflict of interest or commitment may result in disciplinary action up to and including termination.