18.3 Principles of Disclosure, Review, and Management

(Amended 4/05; 10/1/13)

Disclosure, review, and management are critical to the application of conflicts of interest and commitment policies. Under these policies, few activities that represent, or appear to represent, a conflict are actually prohibited. Rather, these rules require conflicts to be disclosed, reviewed, and managed appropriately. Disclosure may take the form of reporting a potential or actual conflict in advance of beginning an activity, at the time a conflict arises, and/or through an annual report of outside interests and activities. Depending on the type of conflict, review of a disclosure to determine whether a conflict exists may be conducted by an employee's DEO or supervisor, or by a University office or committee. If a conflict is identified, a written management plan is required to ensure that conflicts do not interfere with the integrity of employees' performance of University obligations. The appropriate method of disclosure and management varies with the type of activity as described in the Conflicts of Interest and Commitment Procedures Guidance document.