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Conflict of interest and conflict of commitment

Who must complete the annual disclosure survey form(s)?

UA Rule mandates that all University of Ä¢¹½ÊÓƵ employees, as well as students identified as investigators on externally funded grants or contracts, must complete an annual Conflict of Interest/Conflict of Commitment form. Additionally, each full-time employee has a continuing obligation during each year to update their conflict-of-interest form if anything changes during the year, including seeking prior approval.

The following groups are required to comply with these policies, but are exempt from submitting the annual disclosure form(s):

• University student assistants employed solely on an hourly pay basis,
• part-time teaching faculty, and
• employees working less than half-time.

How do I disclose and obtain approval for conflicts that arise during the year that were not in my annual disclosure survey?

Managing conflicts of interest and/or commitments requires timely and accurate disclosure. Any additional potential conflicts of interest commitment must be promptly disclosed throughout the year, by using .   

Remember that this is a pre-approval process:  Any potential conflicts of interest and/or commitments that require permission and approval under the UA Rule must be disclosed and discussed with your supervisor before proceeding with the interest or commitment.

What happens when I disclose a potential conflict?

Potential conflicts of interest that are disclosed through this process will be reviewed by the relevant supervisor(s) and the Office of Academic Affairs, with support as needed from the Compliance and Risk Office (CRO) and the Office of General Counsel (OGC).

Disclosure forms submitted to the Office of Academic Affairs for review should include any relevant additional documents, including any proposed conflict management plans. Where an actual conflict exists, additional actions may be necessary to avoid, eliminate, remediate or manage the conflict.

Where can I get additional information?

• There are a number of resources available to you: UA Rules – Scroll to 3359-11-17
• Conflict of Interest Rule Summary – A concise guide summarizing the UA rules governing Conflict of Interest and Conflict of Commitment
• COI Definitions – This guide provides helpful definitions of numerous terms found throughout the Conflict of Interest/Conflict of Disclosure documentation
• – The Ohio Ethics Commission provides Ohio Ethics Law information, as well as pertinent sections of the Ohio Revised Code – The Ohio Ethics Commission provides Ohio Ethics Law information, as well as pertinent sections of the Ohio Revised Code.

What happens if I do not disclose my conflicts?

Transparency is important. UA relies on employees to timely and accurately raise potential conflicts for review and, where needed, management. Failures to pre-disclose and manage conflicts may be investigated and confirmed violations may result in employee sanctions as per the UA Rule.

QUESTIONS?

If you are having problems with this page, contact University Communications and Marketing through this email.

Questions or concerns regarding potential or actual conflicts of interest can be directed to department chairs, school directors and deans. Questions regarding the disclosure process or UA Rules can be directed to the Office of General Counsel.