Reviewing Conflict of Interest and Conflict of Time and Commitment Disclosures
1. The first role is evaluative. The supervisor should review all responses on the forms. If the employee is required to submit Form B, the supervisor should review the information provided. The supervisor must first determine if there is legitimate cause for concern related to activities that could be actual or perceived conflicts of interest.
The following questions are suggested for this initial determination.
- Is there additional information that is needed before making a determination?
- Do the employee’s relevant financial interests gained from such activities suggest the potential for conflicts or the appearance of conflicts?
- Do the employee’s reported external time commitments exceed permissible levels?
- Does the employee appear to be subject to financial interests or gain that might lead to conflicts or bias?
- Is there any indication that the employee’s obligations to the University are not being met?
- Is the employee involved in a situation that might raise questions of bias, inappropriate use of University assets, or other impropriety?
- Do the current engagements of the employee represent potential conflicts between outside interests (e.g. working on projects simultaneously for competing business entities?)
- Could the proposed activity withstand public scrutiny?
2. After appropriate evaluation, most situations will be found to be;
- Permissible since the disclosed information does not represent a conflict or an inappropriate activity;
- Permissible with modifications aimed at avoiding any conflicts (real or perceived) or inappropriate activities; or
- Inconsistent with University policy and thus not permissible.
3. In a case where the activity is permitted but requires modifications. Options are numerous. Possible options include, but are not limited to:
- Develop a Management Plan to minimize or eliminate any possible conflicts;
- Reformulation of the research work plan to eliminate potential conflicts;
- Divestiture of relevant personal interests that create the conflict;
- Termination or reduction of involvement in the relevant research project that creates the conflict;
- Severance of outside relationships that pose conflicts; and
- Reimbursement to the University for indirect costs and for the use of laboratories, equipment, facilities and other resources.