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

(Amended 1/14/21)

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. Ideally, both related individuals should bring the existence of the relationship to the attention of the first neutral supervisor. However, as soon as one of the related individuals does so, the first neutral supervisor shall begin to develop a management plan. For relationships that develop between persons already in a supervisory relationship or when an organizational change results or would result in a supervisory relationship between two related individuals, disclosure should be made at the earliest possible date and no later than within ninety days after commencement of the conflict of interest situation. 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 relationship with another University employee over whom they exercise decision-making authority. 

To deal with situations in which a conflict of interest might arise through a hiring decision, a management plan must be developed such that the hiring process itself is conducted free of any actual or apparent conflicts of interest. In such cases, disclosure of the relationship should be made at the earliest possible point, in many cases even before the related individual applies for the position.