Conflict of Interest Program Frequently Asked Questions (FAQs)
Q. Who is required to participate in the annual written disclosure program?
A. The roster of employees is determined by the President and Senior Cabinet. It includes nearly 500 employees throughout all divisions of the University. You will be notified if you are required to complete an annual disclosure form.
Q. Is it mandatory?
A. Yes. If you have been selected to complete an annual disclosure form you are required to do so. Regular reporting will be made to each division Vice President regarding the completion rate of those in their division.
Q. Why is this necessary?
A. The University’s Board of Trustees adopted a formal Conflict of Interest Policy in 2008 that requires annual disclosures from select employees. Such policy was adopted in accordance with expectations established by the Internal Revenue Service governing non-profit, tax-exempt organizations
Q. If I filled out a form last year and nothing has changed, do I have to fill out another one?
A. Yes. The annual disclosure process is designed to formally capture all matters occurring since the last annual disclosure and those matters that are still on-going.
Q. When is the disclosure form due?
A. January 15, 2023
Q. What if I don't have access to a computer?
A. Please contact the Office of General Counsel at x5379 to discuss.
Q. Who will see my disclosure?
A. The Vice President responsible for the Division of Service to which you are assigned, the Office of General Counsel, and when applicable, the Provost and/or President.
Q. Will my disclosure be kept confidential?
A. All disclosures are made in confidence and every effort will be made to protect the confidentiality of the disclosure. Such disclosures may, however, be shared with your supervisor and others where necessary to meet the requirements of the Conflict of Interest Program and Policy.
Q. I work in an area where University services are available for employee use (i.e. use of rec center or library services) and I utilize those services in accordance with university policy, is this an item that should be disclosed?
A.No. If, for example, you work in the library and use your ID or library card to take books out of the library, you do not need to include this in your disclosure.
Q. Are all conflicts forbidden?
A. No, but such must be properly disclosed, evaluated and approved by senior management to ensure controls are in place to manage and monitor the conflict.
Q. How is "immediate family" defined?
A. Immediate family for purposes of filling out the disclosure is defined as your spouse, or domestic partner (consistent with University health benefits policy and procedure) and dependent children, including stepchildren.
Q. I have other questions that are not answered here, who can I contact to answer them?
A. Contact the Office of General Counsel at X5379 and a representative will assist.
