Conflict of Interest

Applies to:	Original Policy Date:	Date of Last Review:	Approved by:
All employees, excluding student employees	December 2014	September 2026	Dr. John Nicklow, President

Policy Owner: Human Resources

Policy Purpose

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.

Policy Scope

This policy applies to all university employees but excludes conflict of interest related to funded research projects, which are governed by the Conflict of Interest for Funded Research Projects policy.

Policy Statement

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.

Definitions

HRIS (Human Resource Information System): software used to manage and streamline HR processes.

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 judgment 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 an example of conflicts of interest and commitment.

Financial Interests:

• An employee or member of their immediate family has a 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 with which the university may establish services, 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 is in competition with the university.
• An employee’s work for a secondary employer involves or results in frequent or extended absences from the 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 admission 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, work activity, or self-employment in addition to an employee's position with the university, including during periods of approved 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.

Procedures/Guidelines

New Employees

During onboarding, new university employees receive the Conflict of Interest and Commitment Disclosure Form through the HRIS. Employees are required to complete the form, and the completed form is maintained in the HRIS.

Existing Employees

All university employees are required to complete the Conflict of Interest and Commitment Disclosure Form in the HRIS upon hire and annually thereafter. In addition, employees must complete a new disclosure whenever an actual, perceived, or potential conflict of interest or commitment arises during the year. Employees should discuss any new actual, perceived, or potential conflicts of interest or commitment with their supervisor and/or Human Resources, as appropriate. This requirement is particularly important when an employee seeks or accepts employment, consulting work, or other outside activities that may create a conflict of commitment or otherwise interfere with their responsibilities to the university.

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.

Compliance Reference

SACSCOC 1.1

Responsibilities

All employees are responsible for disclosing all actual, perceived, and potential conflicts of interest.

Human Resources and supervisors are responsible for consulting with employees regarding conflicts of interest.

The Office of General Counsel, Human Resources, and the Office of the Provost are responsible for the review and acknowledgment of conflict of interest disclosures, including the establishment of management plans to mitigate risk associated with those conflicts.

Enforcement

Failure to disclose any actual, 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.