Home > III. Human Resources

Chapter 8 – Conflict of Interest in Employment (Nepotism)

(Regents 4/20/77; approved Faculty Senate 4/95; Staff Executive Council 7/95; President 9/95; amended 12/04; 4/17; 7/1/17; 1/14/21; 4/1/25)

Effective April 1, 2025, this policy has been revised. For individual changes, see the redlined version.

Note: This chapter is one of several that address conflicts of interest of various types at the University of Iowa. Others include: II-5 Consensual Relationships Involving Students, which addresses faculty-student relationships that are either prohibited or discouraged due to role conflicts; and II-18 Conflicts of Commitment and Interest, which addresses time conflicts, role conflicts in the workplace, and financial conflicts of interest. See also II-18.8 Other University of Iowa Policies Related to Conflict of Interest for a complete list of policies that address or are related to conflicts of interest.

8.1 Rationale

(Amended 4/1/25)

It is the policy of the university that conflicts of interest must be avoided where possible, and otherwise disclosed and managed. The University of Iowa and its employees are committed to the principle of objective, fair treatment of all employees. Accordingly, it is crucial that university activities be conducted in an atmosphere that is free of actual or potential conflicts of interest that compromise this principle. This policy protects the integrity and objectivity of university employees in the performance of their university obligations, and supports a workplace environment based in fairness. Other types of conflicts of interest may be managed under university policies as listed in III-8.12.

8.2 Definitions

(Amended 4/1/25)
  1. A "conflict of interest in employment" at the University of Iowa arises when 1) an individual University of Iowa employee has the responsibility to make, or participate actively in making, decisions or recommendations relating to the employment status of another individual University of Iowa employee (hereafter, "decision-making responsibility") and 2) these two individuals (hereafter “associated individuals”) have a current or former relationship occurring outside the work setting that would make it difficult for the individual with the decision-making responsibility to be objective, or that for a reasonable person would create the appearance that such an individual may not be objective. 
  2. “Decision-making responsibility” includes but is not limited to situations when there is any reporting line between two associated individuals. For the purposes of these rules, decisions or recommendations related to employment status include those related to hiring, salary, resource allocation including grant funding, working conditions, working responsibilities, evaluation, promotion, and termination.
  3. Examples of relationships that give rise to “associated individuals” include, but are not limited to, the following:
    1. relationships by blood, adoption, marriage, or domestic partnership: partner, parent, child, sibling, first cousin, uncle, aunt, nephew, niece, spouse, brother- or sister-in-law, father- or mother-in-law, son- or daughter-in-law, step-parent, or step-child; or
    2. romantic and/or sexual relationships or intense personal friendships or conflicts; or
    3. significant external business relationships.
  4. For purposes of this policy, the "first neutral supervisor" is the person (usually the director, departmental executive officer, divisional head, dean of the college, or vice president in charge of the department, college, or unit) immediately superior to the one of the two associated individuals who, if there were no conflict of interest, would have decision-making responsibility relating to the employment status of the other associated individual. 
  5. For purposes of this policy, the “university official” is the university administrator who has primary responsibility for approval of employment decisions regarding the associated individuals, and is typically the dean or vice president, or their designee, who holds administrative responsibility for the college or organizational unit in which the associated individuals are employed.

8.3 Scope of Policy

(Amended 4/1/25)

These provisions apply to full-time, part-time, regular, and temporary faculty and staff, and student employees and persons with fellowships which involve employment at the university who meet the definition of associated individuals, as defined in III-8.2, at any time during their employment or when they seek employment at the university.

In cases where the individual over whom the other individual has responsibilities to make decisions or recommendations related to employment is compensated in the amount of $1,800 or less in any fiscal year, a formal management plan is not required but responsibility for approving employment matters, including time records, must be assigned to an alternative, non-conflicted supervisor.

8.4 Committee on the Conflict of Interest in Employment

(Amended 4/1/25)

The Committee on Conflict of Interest in Employment (“Committee”) will review and consider for approval management plans that are developed as described below. The Committee may approve or deny proposed management plans.

The Committee shall consist of four members appointed by the Faculty Senate and three members appointed by the Staff Council. Members of the Committee shall be appointed for staggered three-year terms, but no person may be appointed for more than two consecutive terms. The Associate Provost for Faculty and the Chief Human Resources Officer or their designees shall serve as co-chairs of the Committee. Committee members shall not participate in the development and approval of a management plan or the oversight of a management plan if 1) they are related to either of the associated individuals; 2) they participated in the development of the management plan in their unit of employment; 3) their conditions of employment could be affected by a management plan; or 4) some other conflict of interest exists. Decisions of the Committee shall be made by majority vote of the Committee members voting on the decision. 

All meetings and deliberations of the Committee shall be confidential. All written materials reviewed or created in the development of a management plan shall be confidential. One of the Committee's co-chairs shall keep on file the Committee's official copy of all management plans. Any information disclosed by either of the associated individuals for the purpose of developing the management plan shall be used solely for that purpose. However, faculty, staff, and students who are in positions to be affected significantly by a conflict of interest in employment  (typically, those who interact  directly with the associated individuals in the context of their work) shall be informed of the existence of the management plan and shall be provided with information regarding the appropriate person(s) to whom they may bring relevant concerns. In most cases, this will be the first neutral supervisor for faculty and staff, although departmental human resource representatives or the Director of Undergraduate or Graduate Studies may be the more appropriate person for staff and students, respectively, in some units.

8.5 Policy

(Amended 4/1/25)

It is the policy of the University of Iowa that conflicts of interest must be avoided where possible. The decision to manage a conflict of interest in employment rather than avoid it must be based on a sound institutional reason. The university official as defined in III-8.2 has the responsibility of determining whether such a sound institutional reason exists. If such a reason exists, associated individuals can be employed, or can continue to be employed, by the university only if a management plan is developed, approved, and implemented as described in III-8.8 below.

An individual is not deemed to have decision-making responsibility (and therefore no conflict of interest in employment exists) if that individual's participation in employment-related decisions affecting the other associated individual is limited to routine approvals and the individual is not required to exercise  discretion in the decision-making processes. The university official as defined in III-8.2 has the responsibility for determining whether a conflict of interest in employment exists. If any question arises whether an individual's participation is greater than is permitted by this section, the Committee should be consulted for its consideration and recommendation (see III-8.3 above). 

Where the associated individual with decision-making responsibility is a dean, vice president, other member of the President’s cabinet, or head coach, the Committee must approve the university official’s determination as to whether a conflict of interest in employment exists, and whether a sound institutional reason exists to manage the conflict. Once determined, the Committee must review and approve the proposed management plan as outlined in III-8.8 below. 

8.6 Occasional or Irregular Conflicts of Interest

(Amended 4/1/25)

If a conflict of interest in employment is occasional or irregular (e.g., a tenure or promotion vote), there must be a mechanism in place for managing the conflict. Recusal typically is required in any situation that involves a discussion and/or decision that could result in a direct benefit to an associated individual. In such cases, the disclosure and recusal or other management plan must be documented.

8.7 Identification of and Initial Steps to Address Conflicts of Interest in Employment

(Amended 1/14/21; 4/1/25)
  1. If the conflict of interest in employment is not occasional or irregular but is ongoing so that recusal is not a reasonable mechanism for managing the conflict, other mechanisms (see https://hr.uiowa.edu/policies/conflict-interest-employment) must be adopted. The process to manage the conflict is initiated by notification of the relationship. Both associated individuals must notify the first neutral supervisor of the relationship. As soon as one of the associated individuals does so, the first neutral supervisor must comply with the process outlined below and document the outcome of each required step.
    1. Consult with the appropriate university official, as defined in III-8.2, to evaluate whether an actual or potential conflict of interest in employment exists.
    2. If no actual or potential conflict of interest in employment is found, notify the associated individuals of the decision and that no further action is needed. If an actual or potential conflict of interest in employment is found, consult with the appropriate university official as to whether a sound institutional reason exists to manage the conflict.
    3. If a sound institutional reason is found to manage an actual or potential conflict of interest in employment, develop a management plan (see III-8.8) in consultation with their senior human resources representative and/or associate dean following the process set forth in 8.8 below. If no sound institutional reason can be identified to manage an actual or potential  conflict of interest in employment, the conflict must be avoided following the process set forth in III-8.9 below.
  2. For relationships that develop between associated individuals  already in a supervisory relationship or when an organizational change results or would result in a supervisory relationship between two associated individuals, disclosure must be made at the earliest possible date and no later than twenty business days after identification of the conflict of interest. In addition, faculty and staff who submit an online Annual Disclosure of Outside Professional Activities and Interests in the eCOI system as outlined in II-18.5.e(5) will be asked to indicate whether they have a personal or external business relationship with another university employee over whom they exercise decision-making authority. 
  3. To deal with situations in which an ongoing conflict of interest might arise through a hiring decision, the associated individual must not be involved in discussions and/or decisions during the selection or hiring process. In such cases, disclosure of the relationship that might give rise to a conflict of interest in employment must be made at the earliest possible point, in many cases even before the associated individual applies for the position. 
  4. University administrators or supervisors who become aware of an actual or potential conflict of interest in employment must refer the matter to the first neutral supervisor or the appropriate Senior HR Leader in the unit where the conflict exists.

8.8 Management Plans

(Amended 4/1/25)
  1. A management plan will ensure that the associated individual with decision-making responsibility is removed from the decision-making processes that affect the employment status of the other associated individual. In addition, the management plan must include the sound institutional reason to manage, rather than avoid, the conflict.

    A template describing the elements of a management plan is available at https://hr.uiowa.edu/policies/conflict-interest-employment. In addition, the co-chairs of the Committee on the Conflict of Interest in Employment (see III-8.3 above) are available for consultation regarding development of a management plan.
  2. A neutral supervisor superior to the first neutral supervisor may develop the management plan.
  3. The associated individuals may be consulted by the department in developing a management plan, but the department is responsible for the final development of a management plan. The associated individuals must sign the management plan document to acknowledge their awareness of the plan.
  4. The management plan shall be reviewed and approved by the university official as defined in III-8.2, and then submitted to the Committee.
  5. The Committee shall evaluate the proposed management plan, considering the plan’s effectiveness in providing for objective decision making, creating and maintaining an atmosphere of fairness, providing consistency in the treatment of employees, and allowing for the effective and efficient operation of the unit(s) in which the associated individuals are employed. The Committee may approve or reject the proposed management plan. If the Committee rejects the proposed management plan, the Committee will inform the department of the reasons for rejection and may make recommendations  for modifications to improve the management plan's probable effectiveness in managing the conflict of interest in employment.
  6. If the Committee recommends modifications to the proposed management plan, the recommendations shall be made to the university official as defined in III-8.2, and the unit may resubmit a modified management plan. If the Committee approves the management plan, the university official is responsible for implementation of the management plan.
  7. The Committee shall evaluate, annually or upon request of any individual who believes they are affected adversely by the management plan, the effectiveness of the established plan created to manage the conflict of interest in employment. As part of the annual evaluation, the department will survey faculty, staff, and students who are in positions to be affected significantly by the conflict of interest in employment as to whether there are any concerns or issues related to the management plan. The Committee may recommend continuation, revisions as appropriate, or may reject continuation of the management plan. The Committee’s decision shall be submitted to the university official to oversee implementation.

8.9 When a Management Plan Cannot Be Developed, Approved, and/or Implemented

(Amended 4/1/25)

The development of a plan to manage a conflict of interest in employment should proceed expeditiously. If  a management plan cannot be developed, approved, and/or implemented within six months of the notification of the relationship of the associated individuals, one of the associated individuals must leave their position at the university (preferably through transfer) not later than one year after notification of the conflict. 

8.10 Policy Violations and Complaint Process

(Amended 4/17; 7/20/22; 4/1/25)
  1. Violations of this policy include:
    1. concealing or failing to disclose one’s own conflict-of-interest relationship;
    2. willful failure or refusal to cooperate with an approved management plan;
    3. failure of a university administrator to refer a matter as described in III-8.7;
    4. or failure of a first neutral supervisor or other university administrator to implement a management plan in a timely manner as described in III-8.9.
  2. Complaints regarding potential violations of this policy shall be referred to the appropriate Associate Dean for Faculty (for faculty), or to the Senior HR Leader or other appropriate institutional official (for staff or student employees) who shall investigate the matter immediately to determine whether any conflict of interest in employment exists and, if so, whether a management plan should be developed; or if any other of the above potential policy violations may exist. The person investigating shall document their findings and refer the matter to the appropriate university official for any necessary action. If a management plan is already in place, the university official will evaluate its effectiveness. Upon conclusion of the investigation, the person investigating shall advise the complainant that the report has been reviewed.
  3. Violations of this policy may subject the employee to disciplinary action.
  4. Any proposed disciplinary actions resulting from violations of this policy:
    1. by faculty members will be governed by III-29 Faculty Dispute Procedures;
    2. by staff members will be governed by applicable Regent Merit System Rules and university policies, including III-16 Ethics and Responsibility Statement for University Staff, and the applicable grievance procedures, including III-28 Conflict Management Resources for University Staff;
    3. by graduate assistants, when dismissal is sought, will be governed by the procedure for dismissal of graduate assistants (III-12.4). When sanctions other than dismissal are imposed by the dean of the employing college, a graduate assistant may appeal through those procedures established for graduate assistant employees;
    4. by students will be governed by the Code of Student Life and Accountability Procedure.

8.11 Grievances

(Amended 7/1/17; 7/20/22; 4/1/25)

Employees who are subject to a management plan and wish to challenge administrative actions that are taken pursuant to this policy may do so following the appropriate policy for their employment status: specifically, for faculty in the tenure track or any of the specialized tracks, the Faculty Dispute Procedures (III-29); for staff, III-28 Conflict Management Resources for University Staff; for graduate assistants, the Graduate Student Employment Agreement; and for other student employees, the Grievance Procedure for Biweekly Student Employees (III-30) .

8.12 Other University of Iowa Policies Related to Conflicts of Interest

(4/1/25)
  1. II-4 Sexual Harassment and Sexual Misconduct
  2. II-5 Consensual Relationships Involving Students
  3. II-18 Conflict of Commitment and Interest
  4. II-19 Acceptable Use of Information Technology Resources
  5. II-27.6 Policy on Ethics in Research
  6. II-33 Use of University Name
  7. II-27.10 University of Iowa Authorship Policy
  8. II-35 Prohibition on Giving and Receiving Gifts
  9. III-15 Professional Ethics and Academic Responsibility
  10. III-17.7 Supplemental Activities and Extra Compensation
    1. III-17.17(1) Use of University Supplies
    2. III-17.17(2) Usurpation of Universities Opportunities
    3. III-17.17(3) Royalties from Course Materials
  11. V-11 Purchasing
    1. V-11.14 Conflict of Interest
    2. V-11.15 Purchases from University Faculty or Staff
    3. V-11.22 Items Which May Not Be Purchased
  12. V-30 Intellectual Property Policy 
  13. Start-Up Company Conflict of Interest Issues/Policies:
    http://coi.research.uiowa.edu/files/coi.research.uiowa.edu/files/docs/start_up_guide_-_revised_052012.pdf
  14. University of Iowa Health Care Conflict of Interest and Conflict of Commitment Policy: 
    https://uihc.org/conflict-interest-policy