Home > III. Human Resources > Ch.8 - Conflict of Interest in Employment (Nepotism)

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.